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2016 (11) TMI 377 - ITAT MUMBAIDisallowance of research & development expense - Held that:- The copies of transportation vouchers were also submitted before us to show that all these evidences were brought before the AO evidencing transportation of saplings and other related material. Nothing has been brought on record by the lower authorities to reject these evidences. No further query was raised in this regard by the lower authorities which was left to be addressed by the assessee. We find that the disallowance has been made without brining any cogent material on record to reject the details and evidences submitted by the assessee. The disallowance cannot be made only on the ground that results of the research were not shown by the assessee during the year under consideration. The benefit of research may or may not yield in the year under consideration. But, that would not determine allowability of the expenses or otherwise. Thus, taking into account totality of facts and circumstances of the case, the action of lower authorities in disallowing these expenses was not justified and therefore, same is reversed and AO is directed to allow the claim - Decided in favour of assessee.
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