PR COMMISSIONER OF INCOME TAX CENTRAL 1 MUMBAI vs MACELODS PHARMACEUTICALS LIMITED AY 2012-13

CNR No : HCBM020207842023 34-ITXA-267-2024.DOC 2026:BHC-OS:15315-DB IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 267 OF 2024 Pr. Commissioner of Income Tax, Central-1, Mumbai ...Appellant Versus Macelods Pharmaceuticals Ltd. AY 2012-13 ...Respondents _________ Mr. Akhileshwar Sharma for Appellant. Dr. K. Shivaram, Sr. Adv. a/w Shashi B. for Respondent. __________ CORAM: G. S. KULKARNI & AARTI SATHE, JJ. DATE: 03 JULY 2026 Oral Judgment (Per:- G. S. Kulkarni, J.) 1. This appeal, filed under Section 260A of the Income-Tax Act, challenges an order dated 31 January 2023 passed by the Income-Tax Appellate Tribunal, Mumbai Bench, whereby the Revenue’s appeal against the common order dated 27 June 2018 passed by the Commissioner of Income-tax (Appeals), Mumbai, has been rejected. The assessment year in question is assessment year 2012-13. 2. The only question of law as urged on behalf of the revenue in this appeal is as under: “Whether, on the facts and circumstances of the case in law, the ITAT justified in holding the research and development expenditure as allowable deduction under the provision of Section 80IB/IC of the Income-Ta