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आयकर अपीलीय अधिकरण, ‘सी’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI ्ቦी एबी टी व्ቅी, न्यायय्ቅ सदस्य एवं ्ቦी एस. आर. रघुनाथा, लेखा सदस्य के सम्ቌ BEFORE SHRI ABY T VARKEY, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.2481/Chny/2026 ननिाारण वर् ा / Assessment Year: 2018-19 AEON Formulations Pvt.Ltd. The Income Tax Officer Plot No.21, Door No.2 vs. Corporate Ward 2(1)

Venkateswara Nagar Chennai.

Velu Naicker Street, Ramapuram Chennai – 600 089.

[PAN: AAHCA4128R] (्ቚत्यथी/Respondent)

(अपीलाथी/Appellant)

अपीलाथी की ओर से/Appellant by : Shri. R.Venkata Raman, C.A. &

Shri. K.Vishva Padmanabhan, CA ्ቚत्यथी की ओर से/Respondent by : Shri. Beesam Narasing Rao, JCIT सुनवाई की तारीख/Date of Hearing : 23.09.2026 घोर्णा की तारीख/Date of Pronouncement : 12.10.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM :

This appeal by the assessee is directed against the order dated

12.02.2026 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)”], arising out of the assessment order dated 22.02.2021 passed by the National e-Assessment Centre, Delhi [hereinafter referred to as “the AO”] u/s.143(3) of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year (A.Y) 2018-19.

:-2-: ITA. No:2481/Chny/2026.

2. The assessee has raised the following grounds of appeal:

1. That the Learned Commissioner of Income Tax (Appeals), NFAC, Delhi [“Ld.

CIT(A)”] erred in law and on facts in upholding the disallowance of Rs.2,45,55,010/- made by the Assessing Officer under section 35(2AB) of the Income-tax Act, 1961 [“the Act”], without appreciating that such disallowance was made beyond the permissible scope of the limited scrutiny assessment; consequently, the said addition is without jurisdiction, bad in law, and liable to be deleted in full.

2. That the Ld.CIT(A) ought to have quashed the impugned assessment order dated 22.02.2021 passed by the Assessing Officer u/s.143(3) of the Act as the same was passed without obtaining the prior approval of the administrative PCIT.

3. Without prejudice to the above, that the Ld.CIT(A) ought to have deleted the addition of Rs.2,45,55,010/- made by the Assessing Officer in full.

3. The brief facts of the case as emanating from the records are that the assessee is a company engaged in the business of formulations research and manufacture of pharmaceutical, nutraceutical and ayurceutical products. For the impugned assessment year, the assessee filed its return of income electronically on 31.10.2018 declaring a loss of Rs.82,11,268/-, inter alia, after claiming deduction u/s.35(2AB) of the Act in respect of expenditure incurred on its in-house Research and Development facility. The case of the assessee was selected for Limited Scrutiny under CASS specifically for examination of the following two issues:

i. Deduction on account of donation for Scientific Research ii. Duty Drawback Accordingly, notice u/s.143(2) of the Act was issued on 22.09.2019, followed by statutory notices u/s.142(1) of the Act. The assessee duly complied with the notices and furnished the details and documents called for during the course of assessment proceedings. During the course of assessment, the AO proceeded to examine the assessee’s claim for weighted deduction u/s.35(2AB) of the Act in respect of expenditure incurred on its own in-house Research and Development facility. The assessee had claimed deduction of Rs.3,21,66,010/- u/s.35(2AB) of the Act. The AO called upon the assessee to furnish Form No.3CL issued by the prescribed authority, namely, the Department of Scientific :-3-: ITA. No:2481/Chny/2026.

and Industrial Research (“DSIR”). As per Form No.3CL, the eligible Research and Development expenditure for the relevant assessment year was quantified at Rs.50.74 lakhs, comprising capital expenditure of Rs.31.41 lakhs and revenue expenditure of Rs.10.33