JK Agri Genetics receives income tax order on R&D expense disallowance
JK Agri Genetics Limited received an income tax order on 17th April 2026 from the Commissioner of Income Tax – Appeals, disallowing ₹1.50 crore of labour expenses related to R&D activities for FY 2017-18. The order results in a tax demand of ₹0.52 crore, which will be adjusted against the company's available MAT credit with no cash outflow impact. The company is considering filing an appeal before the Income Tax Appellate Tribunal within the 60-day prescribed timeline.

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JK Agri Genetics Limited has disclosed receiving an income tax order from the Commissioner of Income Tax – Appeals regarding the disallowance of research and development expenses for Financial Year 2017-18. The communication was received on 17th April 2026 through the National Faceless Appeal Centre (NFAC), Delhi.
Background of the Tax Matter
The current development stems from an ongoing tax dispute that began with the company's income tax return filed for Financial Year 2017-18. In April 2021, the IT Department passed an assessment order disallowing expenses of ₹9.89 crore, specifically the weighted deduction of 150% under section 35(2AB) of the IT Act on R&D expenses of ₹6.59 crore. The initial tax impact was calculated at ₹3.42 crore, with the disallowance based on non-receipt of Form 3CL from the Department of Scientific and Industrial Research (DSIR).
Current Order Details
| Parameter: | Details |
|---|---|
| Order Type: | Order U/S 250 of Income Tax Act, 1961 |
| Authority: | Commissioner of Income Tax – Appeals |
| Date Received: | 17th April 2026 |
| Disallowed Amount: | ₹1.50 crore (labour expenses) |
| Tax Demand: | ₹0.52 crore |
In April 2023, DSIR had disallowed only ₹1.50 crore towards labour expenses that were outsourced in nature and subsequently filed Form 3CL with the IT Department. Based on this development and the company's appeal, the Commissioner of Income Tax (Appeals) has now passed an order confirming the disallowance of ₹1.50 crore of labour expenses as per the Form 3CL issued by DSIR.
Financial Impact
The financial implications of this order are limited due to the company's tax position:
- Demand Amount: ₹0.52 crore (including applicable interest)
- Cash Impact: No cash outflow expected
- Adjustment Mechanism: The demand will be adjusted against available MAT credit
The company has confirmed that the demand amount will be set off against its existing Minimum Alternate Tax (MAT) credit balance, eliminating the need for any cash payment.
Company's Response Strategy
JK Agri Genetics Limited is actively considering its legal options in response to this order. The company has indicated that it is contemplating filing an appeal against the Commissioner (Appeals) order before the Income Tax Appellate Tribunal (ITAT). The prescribed timeline for filing such an appeal is within sixty days of receipt of the order.
Compliance and Disclosure
The company has made this disclosure in compliance with Regulation 30 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. The disclosure confirms that no penalties, restrictions, or sanctions have been imposed pursuant to this communication, and no aberrations or non-compliances have been identified by the tax authority in the current order.
Historical Stock Returns for JK Agri Genetics
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -2.76% | +3.28% | +10.57% | -26.73% | -6.22% | -36.07% |
Will JK Agri Genetics proceed with filing an appeal to ITAT within the 60-day deadline, and what are the potential outcomes?
How might this tax precedent affect other agri-genetics companies claiming similar R&D expense deductions under section 35(2AB)?
What changes could JK Agri Genetics implement in its R&D expense structure to avoid future disallowances of outsourced labor costs?
































