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Case lawCBDT Circulars & Instructions › Statutory position — s.35(1)(i): revenue expenditure on scientific research needs no approval and is allowed in full
CBDT Circulars & InstructionsCuts both waysValidity unconfirmeds.35s.35(1)(i)s.35(1)(iv)s.35(2)s.35(2)(iv)s.35(2AB)s.35(3)s.37(1)s.43(4)s.32

Statutory position — s.35(1)(i): revenue expenditure on scientific research needs no approval and is allowed in full

The DSIR would not certify part of my client's research spend. Is there a provision that allows it without any approval at all?

The DSIR would not certify part of my client's research spend. Is there a provision that allows it without any approval at all?

Yes. Section 35(1)(i) allows, in computing business income, "any expenditure (not being in the nature of capital expenditure) laid out or expended on scientific research related to the business". It carries no approval requirement of any kind — no DSIR approval of a facility, no Central Government approval of an institution — and no weighting: the deduction is the expenditure, at a hundred per cent. It is the natural fallback wherever a weighted claim under s.35(2AB) is cut down to the figure in Form 3CL, and since AY 2021-22 it gives exactly the same number as s.35(2AB) for revenue expenditure, because the s.35(2AB) proviso has taken that deduction down to the expenditure incurred.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2020-04-01, reported as Section 35 as printed on the Income Tax Department's section page stamped "Year: 2025"; https://incometaxindia.gov.in/w/section-35-64. It bears on section 35, section 35(1)(i), section 35(1)(iv), section 35(2), section 35(2)(iv), section 35(2AB), section 35(3), section 37(1), section 43(4), section 32 of the Income Tax Act 1961, in Deductions & Disallowances matters.

Validity check could not be completed. The words of s.35(1)(i), s.35(1)(iv), s.35(2)(iv) and s.35(3) are the words printed on the Income Tax Department's section page stamped Year: 2025; the same page was fetched twice for different sub-sections and the clause (i) and clause (iv) text was returned in the same words on both occasions. The label is 'unverified' rather than 'good law' because two supporting elements were not verified from a current primary source: the current text of the Explanation to s.35(1) on pre-commencement research expenditure, which was not transcribed at all, and the current text of s.43(4), which is taken here from a 2013 judgment reproducing it. No case squarely construing s.35(1)(i) was read.

Why it matters

The library has carried nothing on s.35(1)(i), and it is the provision most often overlooked in exactly the disputes it answers. Where the DSIR quantifies less than was spent, the assessee has three ways to reach the excess: attack the quantification, which after 1 July 2016 has become much harder; claim the excess under s.37(1), which the Delhi Tribunal allowed in Anand NVH Products; or claim it under s.35(1)(i) as revenue expenditure on scientific research related to the business, which is what the assessee in EID Parry (India) had asked the lower authorities to do. The scope of 'scientific research related to the business' is not narrow — s.43(4) makes it include any research which may lead to or facilitate an extension of the business, as the Karnataka High Court applied in Talisma Corporation on the capital limb — and 'related to the business' is a wider expression than 'for the purposes of the business'. Two limits matter. First, s.35(1)(i) is confined to expenditure not in the nature of capital expenditure; capital spend goes to s.35(1)(iv) read with s.35(2), and that carries the s.35(2)(iv) bar on also claiming depreciation under s.32(1)(ii) on the same asset. Second, s.35(3) provides that if a question arises whether, and to what extent, any activity constitutes scientific research or an asset is being used for scientific research, the Board refers it to the prescribed authority, whose decision is final for an activity other than one under clauses (ii) and (iii) of s.35(1) — so the officer has a route to a binding determination, but it is that route and not a unilateral disallowance.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

Not yet CA-verified. This entry was found through the sources listed under the Sources tab, and the summary reflects what those sources say. Nobody has yet read the full judgment and signed it off. Check the source before relying on it.

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