PCIT Rightly Invoked : AO Ignored Mandatory DSIR Form 3CL for R&D Deduction

Pharmanza Herbal Pvt. Ltd Vs PCIT (ITAT Ahmedabad) PCIT Was Right! AO’s “Allow First, Verify Never” Approach Invites 263- Form 3CL is Non-Negotiable – AO Can’t Grant 35(2AB) on Assumptions, 263 Sustained AO Allowed R&D Deduction Without Verifying Form 3CL – ITAT Confirms 263 as AO Ignored Mandatory Law! Assessee Company filed its return declaring income of ₹4.81 Cr. AO completed scrutiny assessment u/s 143(3) r.w.s. 143(3A) & 143(3B) accepting returned income. During assessment, AO allowed deduction of ₹1,80,11,055 u/s 35(2AB), being 150% of in-house R&D expenditure...