Mitsui Kinzoku Components India Pvt. Ltd. Vs Secretary, Department of Scientific and Industrial Research (Delhi High Court)
The Delhi High Court considered a writ petition filed by a company engaged in manufacturing and selling catalytic converters for the automobile industry. The petitioner sought quashing of orders dated 11 April 2025 and 14 November 2025 issued by the respondent authority rejecting its application for issuance of Form 3CL for financial years 2017-18, 2018-19, and 2019-20, corresponding to assessment years 2018-19, 2019-20, and 2020-21. The petitioner also challenged the rejection of its request for permission to dispose of research and development assets acquired for scientific research purposes.
The petitioner operated production facilities in Bawal, Haryana and Sanand, Gujarat, and maintained an in-house Research and Development (R&D) unit at Bawal, Haryana, which had been recognized by the Department of Scientific and Industrial Research (DSIR). The petitioner had incurred expenditure relating to the Haryana-based R&D unit and had applied for Form 3CL, which was required to claim deductions under Section 35(2AB) of the Income Tax Act, 1961 for scientific research expenditure. The petitioner had also filed an application seeking prior approval for disposal of one R&D equipment used in the research facility. Both requests were rejected by the Department through the impugned orders.
