VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — the s.35(2AB) and s.35(2AA) weighting: two hundred, then one hundred and fifty, then one hundred per cent
CBDT Circulars & InstructionsCuts both wayss.35s.35(2AB)s.35(2AA)s.35(2)(iv)s.35(3)s.32

Statutory position — the s.35(2AB) and s.35(2AA) weighting: two hundred, then one hundred and fifty, then one hundred per cent

What weighting do I put on my client's in-house R&D spend, and from which assessment year did each rate change?

What weighting do I put on my client's in-house R&D spend, and from which assessment year did each rate change?

For s.35(2AB) the weighting was two hundred per cent, fell to one hundred and fifty per cent from AY 2018-19, and falls to a hundred per cent — that is, no weighting at all — for expenditure incurred in a previous year relevant to an assessment year beginning on or after 1 April 2021. The current text reads "a deduction of a sum equal to one and one-half times of the expenditure so incurred", cut down by a proviso which for AY 2021-22 onwards makes the deduction "equal to the expenditure so incurred". Section 35(2AA), for sums paid to a National Laboratory, University, Indian Institute of Technology or specified person for approved research, follows the same shape: one and one-half times the sum paid, reduced by a second proviso to the sum so paid for an assessment year beginning on or after 1 April 2021.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text) on 2018-04-01, reported as Section 35 as printed on the Income Tax Department's section pages stamped "Year: 2025" and "Year: 2022"; https://incometaxindia.gov.in/w/section-35-64 and https://incometaxindia.gov.in/w/section-35-60. It bears on section 35, section 35(2AB), section 35(2AA), section 35(2)(iv), section 35(3), section 32 of the Income Tax Act 1961, in Deductions & Disallowances matters.

Still good law. The current words are the words printed on the Income Tax Department's section pages stamped Year: 2025 and Year: 2022, which agree with each other. No later amendment was checked for and none is asserted. Both steps in the weighting are established from amendment footnotes on year-stamped departmental pages (Act No. 28 of 2016, w.e.f. 1-4-2018 for the reduction to one and one-half times; the proviso keyed to 1 April 2021 for the reduction to the expenditure incurred). Any authority stating the two-hundred per cent weighting for AY 2018-19 or later is superseded by amendment on that point.

Why it matters

Almost every published note and every older Tribunal order on s.35(2AB) states a weighting that is wrong for a current year, and a computation carrying two hundred per cent into AY 2018-19 or one hundred and fifty per cent into AY 2021-22 is an overclaim that invites both a disallowance and a s.270A penalty. Two consequences follow for how disputes are run. First, on a Form 3CL quantification dispute, the money at stake for revenue expenditure from AY 2021-22 onwards is not the weighting but only whether the expenditure is allowed at all, and if it is refused under s.35(2AB) it can be claimed at the same hundred per cent under s.35(1)(i) or s.37(1) — which is why the fight has largely moved to the fallback. Second, the gate has not moved: the approval of the in-house facility by the prescribed authority is still required, and s.35(2AB)(3) still bars a company from the deduction unless it enters into an agreement with the prescribed authority for co-operation in the facility and fulfils the prescribed conditions on maintenance and audit of accounts and furnishing of reports. Rule 6(7A), as amended by the Income Tax (Tenth Amendment) Rules, 2016 with effect from 1 July 2016, requires the prescribed authority to report in Part A of Form 3CL on approval of the facility and in Part B on the quantification of the eligible expenditure.

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

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Related

Other authorities on the same sections.