RONALD BELCHAR FERNANDES,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1) & TPS, MANGALURU

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ITA 1770/BANG/2025Status: DisposedITAT Bangalore22 June 2026AY 2019-2021 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay of 221 days, holding that the assessee had sufficient cause and that substantial justice should be preferred over technicalities. The adjustment made by the CPC regarding employees' contribution to provident fund/ESI deposited beyond the due date prior to AY 2021-22 was directed to be deleted.

What were the facts?

The assessee filed an appeal before the ITAT with a delay of 221 days due to a bonafide impression that the appeal should be against the AO's consequential order, not the CIT(A)'s original order. The Tribunal considered the reasons for the delay and the principles of substantial justice.

What were the issues?

Whether the delay in filing the appeal should be condoned, and whether the disallowance of employees' contribution to PF/ESI deposited beyond the due date is valid prior to AY 2021-22.

Which sections of the Income-tax Act were involved?

Section 253(5),Section 36(1)(va),Section 43B,Section 143(1)(a)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

For Appellant: Shri Hemant Pai & Shri Srinath L., A.Rs
Hearing: 25.03.2026Pronounced: 22.06.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. CIT(A)/NFAC dated 8.10.2024 vide DIN & Order No. ITBA/NFAC/S/250/2024-25/1069535310(1) passed u/s 250 of the Income Tax Act, 1961 (in short “the Act”) for the assessment year 2019-20.

2.

The assessee has raised the following grounds of appeal:-

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3.

At the outset, the ld. A.R. of the assessee submitted that there is a delay of 221 days in filing the appeal before this Tribunal. The ld. A.R. of the assessee also drew our attention on application for condonation of delay dated 2.1.26 along with an affidavit in original sworn before the notary public stating the reasons for delay which are reproduced below for ease of reference and record:

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4.

On going through the above application for condonation of delay, we find that the assessee could not file the appeal in time for the reason that the assessee was under a Bonafide impression that since the ld. CIT(A)/NFAC had partly allowed the appeal, an appeal would have to be preferred against the consequential order passed by the AO. Thereafter, the assessee approached the present counsel to seek advice on the OGE passed by the AO, upon which, the assessee was informed that an appeal has to be preferred against the original order passed by the ld. CIT(A)/NFAC instead of order giving effect (OGE) passed by the AO and accordingly the present appeal was filed immediately before this Tribunal with an application for condonation of delay. In view of the above, it was contended that the delay was neither unintentional nor deliberate but arose due to the aforementioned circumstances, which were beyond the assessee’s control and consequently no benefit can be attributed to the assessee in filing the appeal belatedly. He thus prayed to condone the delay and requested to consider the issues raised by the assessee on merits.

5.

On the contrary the ld. D.R. vehemently objected for granting the condonation of delay and submitted that the assessee is very callous in filing the appeal before this Tribunal.

6.

We have perused the details filed by the assessee to justify the delay and we are satisfied that there is no malafide intention on the part of the assessee in filing the appeal belatedly before us. It is to be noted that u/s 253(5) of the Act the Tribunal may admit the appeal filed beyond the period of limitation where it has established that there exists a sufficient cause on the part of the assessee for not presenting the appeal within the prescribed time. The explanation therefore, becomes relevant to determine whether the

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 11 of 21 same reflect sufficient and reasonable cause on the part of the assessee in not filing this appeal within the prescribed time. We have gone through the reasons explained by the assessee in which the assesse was under a bonafide impression that since the ld. CIT(A)/NFAC had partly allowed the appeal, an appeal would have to be preferred against the consequential order passed by the AO. Thereafter, the assessee approached the present counsel to seek advice on the OGE passed by the AO, upon which, the assessee was informed that an appeal has to be preferred against the original order passed by the ld. CIT(A)/NFAC instead of order giving effect passed by the AO and accordingly the present appeal was filed immediately before this Tribunal with an application for condonation of delay.

6.1 While considering a similar issue the Apex Court in the case of Collector, Land Acquisition v. Mst. Katiji and Ors. (167 ITR 471) laid down six principles. For the purpose of convenience, the principles laid down by the Apex Court are reproduced hereunder:

(1) Ordinarily, a litigant does not stand to benefit by lodging an appeal late.

(2) Refusing to condone delay can result in a meritorious matter being thrown at the very threshold and cause of justice being defeated. As against this, when delay is condoned, the highest that can happen is that a cause would be decided on merits after hearing the parties. (3) 'Every day's delay must be explained' does not mean that a pedantic approach should be made. Why not every hour's delay, every second's delay? The doctrine must be applied in a rational, commonsense and pragmatic manner.

(4) When substantial justice and technical consideration are pitted against each other, the cause of substantial justice deserves to be preferred, for the other side cannot claim to have vested right in injustice being done because of a nondeliberate delay. (5) There is no presumption that delay is occasioned deliberately, or on account of culpable negligence, or on account of mala fides. A litigant does not stand to benefit by resorting to delay. In fact, he runs a serious risk.

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 12 of 21 (6) It must be grasped that the judiciary is respected not on account of its power to legalise injustice on technical grounds but because it is capable of removing injustice and is expected to do so.

6.2 When substantial justice and technical consideration are pitted against each other, the cause of substantial justice deserves to be preferred, for the other side cannot claim to have vested right for injustice being done because of nondeliberate delay. Therefore, we have to prefer substantial justice rather than technicality in deciding the issue. As observed by Apex Court, if the application of the assessee for condoning the delay is rejected, it would amount to legalize injustice on technical ground when the Tribunal is capable of removing injustice and to do justice. Therefore, this Tribunal is bound to remove the injustice by condoning the delay on technicalities. If the delay is not condoned, it would amount to legalizing an illegal order which would result in unjust enrichment on the part of the State by retaining the tax relatable thereto. Under the scheme of Constitution, the Government cannot retain even a single pie of the individual citizen as tax, when it is not authorized by an authority of law. Therefore, if we refuse to condone the delay, that would amount to legalize an illegal and unconstitutional order passed by the lower authority.

6.3 Further, in the case of People Education & Economic Development Society Vs ITO reported in 100 ITD 87 (TM) (Chen), wherein held that “when substantial justice and technical consultation are pitted against each other, the cause of substantial justice deserves to be preferred for the other side cannot claim to have vested right in injustice being done because of non-deliberate delay”.

6.4 The next question may arise whether delay was excessive or inordinate. There is no question of any excessive or inordinate when the reason stated by the assessee was a reasonable cause for

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 13 of 21 not filing the appeal. We have to see the cause for the delay. When there was a reasonable cause, the period of delay may not be relevant factor. In fact, the Madras High Court in the case of CIT vs. K.S.P. Shanmugavel Nadai and Ors. (153 ITR 596) considered the condonation of delay and held that there was sufficient and reasonable cause on the part of the assessee for not filing the appeal within the period of limitation. Accordingly, the Madras High Court condoned nearly 21 years of delay in filing the appeal. When compared to 21 years, 221 days cannot be considered to be inordinate or excessive. Furthermore, the Chennai Tribunal by majority opinion in the case of People Education and Economic Development Society (PEEDS) v. ITO (100 ITD 87) (Chennai) (TM) condoned more than six hundred days delay. Therefore, in our opinion, by preferring the substantial justice, the delay of 221 days has to be condoned and accordingly we condone the delay and admit the appeal for adjudication.

7.

Now the brief facts of the case are that the assessee filed his return of income for the AY 2019-20 on 31.10.2019 declaring a total income of Rs.58,58,450/-. The said return was processed and accordingly intimation under section 143(1) of the Act was passed by the CPC on 05.05.2020, wherein the deduction amounting to Rs. 12,32,941/- claimed under section 36(1)(va) of the Act was disallowed on account of delayed remittance of ESI and PF and further denied TDS credit to the extent of Rs. 1,12,319/-. The assessee being aggrieved by the above intimation had filed a rectification request before the CPC on 01.06.2020. However, the CPC passed an order under section 154 of the Act on 24.06.2020 reiterating the contents of intimation issued under section 143(1) of the Act.

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 14 of 21 8. Aggrieved by the aforesaid rectification order passed by the CPC u/s 154 of the Act on 24/06/2020, the assessee preferred an appeal before ld. CIT(A)/NFAC.

9.

The ld. CIT(A)/NFAC heavily relying on the judgment of Hon’ble Supreme Court dated 12.10.2022 in the case of Checkmate Services P. Ltd. Vs. CIT-1 (Civil Appeal No.2833 of 2016 and other CAs) held that for claiming deduction u/s 36(1)(va) of the Act the amounts have to be deposited on or before the due dates and that the non-obstante clause u/s 43B of the Act or anything contained in that provision would not absolve the assesse from its liability to deposit employees’ contribution on or before the due date as a condition for deduction. Further, ld. CIT(A)/NFAC held that the Apex Court decision not only clarifies the matter regarding delayed payment of employees’ share being covered u/s 36(1)(va) r.w.s. 2(24)(x) of the Act and that section 43B of the Act does not come into play in respect of the same. Thus, the decision effectively endorses the amendment made by the Finance Act, 2021 in that the amendment made was clarificatory in nature and had retrospective effect. Accordingly, the ld. CIT(A)/NFAC upheld the disallowance of Rs.14,32,769/- made by the CPC for delayed deposit of employees’ contribution to PF and ESI.

9.1 Further, with regard to assessee’s claim that Rs.1,12,319/- was deducted by Trimax IT Infrastructure & Services Ltd. for which TDS credit was not granted by the CPC, the ld. CIT(A)/NFAC held that in view of the decision of Hon’ble High Court of Gujarat in the case of Devarsh Pravinhai Patel Vs. ACIT Circle-5(1)(1) dated 24.9.2018 directed the AO to give the TDS credit to the extent reflected in Form-16. Accordingly, the appeal of the assessee was partly allowed.

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 15 of 21 10. Again, aggrieved by the order of ld. CIT(A)/NFAC, the assessee has filed the present appeal before this Tribunal.

11.

Before us, the ld. A.R. of the assessee vehemently submitted that the amendment to provisions of section 36(1)(va) r.w.s. 43B of the Finance Act, 2021 by inserting explanation (2) is prospective in nature and would be application only from 1st April, 2021 and hence not applicable for assessment year 2019-20 under consideration. Further, ld. A.R. of the assessee submitted that the proposal for adjustment under the 1st proviso to section 143(1)(a) of the Act was also not served on the assessee, which is a gross violation of principles of natural justice. Further, the ld. A.R. of the assessee submitted that while passing the intimation u/s 143(1) of the Act, on 5.5.2020, the decision of the jurisdictional High Court Karnataka was in favour of the assessee and the decision of the Hon’ble Supreme Court in the case of Checkmate Service P. Ltd. cited (supra) was pronounced only on 12.10.2022. Lastly, the ld. A.R. submitted that the adjustment made u/s 143(1) of the Act is bad in law as it exceeds the limited scope to carry out prima facie adjustments and arithmetical corrections stipulated u/s 143(1) of the Act and consequently, the adjustment made on a debatable issue is illegal and bad in law and accordingly prayed that the intimation passed u/s 143(1) of the Act may be quashed.

12.

The ld. D.R. on the other hand vehemently supported the order of ld. CIT(A)/NFAC and submitted that in view of the judgment of Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. Vs. CIT cited (supra) the ld. CIT(A)/NFAC has good enough reasons for making the disallowance. Lastly, the ld. D.R. submitted that when the Hon’ble Supreme Court renders the decision, it applies from the date of the enactment of a particular

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 16 of 21 provision and accordingly prayed that the action of the CPC may be upheld.

13.

We have heard the rival submissions and perused the materials available on record. It is an undisputed fact that the Hon’ble Supreme Court in the case of Checkmate Services P. Ltd. reported in (2022) 448 ITR 518 (SC) has held that such deduction is not allowable to the assessee if the employees’ contribution is not paid within the due date prescribed under the respective Acts. However, the said judgment was rendered by the Apex Court only on 12.10.2022. Undisputedly, the intimation u/s 143(1) of the Act was passed on 5.5.2020 and the rectification order was passed on 24.6.2020 i.e. way before the pronouncement of judgment of Hon’ble Supreme Court on 12.10.2022. It is also an undisputed fact that prior to the said judgment of the Apex Court, there were divergent opinions of various High Courts on this issue. As rightly contended by the ld. A.R. of the assessee, the Hon’ble High Court of Karnataka had decided the issue at that particular time in favour of the assessee and therefore, the assessee was entitled at that time for the deduction of the employees’ contribution paid belatedly according to the provisions of the respective Act but before the due date of furnishing the return. Thus, prior to 12.10.2022, the decision was in favour of the assessee and it is apparent that intimation u/s 143(1) as well as rectification order u/s 154 of the Act for the AY 2019-20 was passed prior to the decision of Hon’ble Supreme Court. We are of the considered opinion that in the similar facts and circumstances of the case, the coordinate bench of this Tribunal in the case of Shri Chandrakant Shamappa Kontha Vs. DCIT in ITA Nos.2396 & 2397/Bang/2024 vide order dated 9.12.2025 has passed a detailed order, the relevant paragraphs are reproduced below for ease of reference and convenience:

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 17 of 21 “24. We have carefully considered the rival contention and perused the orders of the learned lower authorities. The issue involved in this appeal is the adjustment made by the central processing Centre for assessment year 2019 – 20 and the 2020 – 21 to the total income of the assessee being amount of employee's contribution of the P F and ESIC contribution which are deposited beyond the specified due dates prescribed in the respective acts. . For assessment year 2019 – 20, the intimation was passed under section 143 (1) of the income tax act on 14 July 2020 wherein in annexure of computation of the intimation of business income there is an adjustment/addition to the total income of the assessee at serial No. 14 'that the amounts debited to the profit and loss account to the extent of disallowable under section 36' of ₹ 10,048,794/– was added to the total income. This sum is stated to be in respect of employees' contribution paid towards provident fund and employee state insurance scheme admittedly paid beyond the due date specified under the respective act. Similarly for assessment year 2020 – 21 the intimation under section 143 (1) was passed on 16 December 2021 wherein a sum of ₹ 12,922,206/– was adjusted in similar manner.

25.

Undoubtedly the decision of the honourable Supreme Court in case of checkmate services ltd [ supra ]has held that such deduction is not allowable to the assessee if the employee's contribution is not paid within the due date prescribed under the respective acts. However, said judgement was rendered by the honourable Supreme Court on 12 October 2022 reported in (2022) for 48 ITR 518 (SC) (2023) 6 SCC 451. However, prior to that decision there were divergent opinions of the various high courts. Honourable Karnataka High Court has decided this issue at that particular time in favour of the assessee and therefore the assessee was entitled at that time for the deduction of the employee's contribution paid belatedly according to the provisions of the respective act but before the due date of filing of the return of income. Therefore, prior to 12 October 2022 the decision was in favour of the assessee. It is apparent that the intimation for both these years are passed prior to the decision of the honourable Supreme Court.

26.

It is the provision of the law that that employee's contribution of this respective acts collected by the employer's income of the assessee in terms of provisions of section 2 (24) (x) of the act. Thereafter at the time of deposit of those sums, within the due dates prescribed in the respective act, deduction is allowable under the provisions of section 36 (1) (va) of the act. To this section an explanation – 1 was inserted with effect from 1 April 2021 by The Finance Act 2021 providing that the 'due date' means the date by which the assessee is required as an employer to credit an employee's contribution to the employees account in the relevant fund under any act, rule, order or notification issued there under or under any standing order, award, contract of services or otherwise. Further explanation 5 was also added to the provisions of section 43B of the act by The Finance Act, 2021 with effect from 1 April 2021 providing that "for the removal of doubts, it is hereby clarified that the provisions of this section shall not apply and shall be deemed never to have been applied to a sum received by the assessee from any of his employees to which the provisions of subclause (x) of clause 24 of section 2 applies.

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 18 of 21 27. The memorandum explaining the provision in the Finance Bill, 2021 has referred to the amendment as under:- Rationalization of various Provisions

Payment by employer of employee contribution to a fund on or before due date Clause (24) of section 2 of the Act provides an inclusive definition of the income. Sub-clause (x) to the said clause provides that income to include any sum received by the assessee from his employees as contribution to any provident fund or superannuation fund or any fund set up under the provisions of ESI Act or any other fund for the welfare of such employees. Section 36 of the Act pertains to the other deductions. Sub-section (1) of the said section provides for various deductions allowed while computing the income under the head ̳ Profits and gains of business or profession ‘. Clause (va) of the said sub-section provides for deduction of any sum received by the assessee from any of his employees to which the provisions of sub-clause (x) of clause (24) of section apply if such sum is credited by the assessee to the employee's account in the relevant fund or funds on or before the due date.

Explanation to the said clause provides that, for the purposes of this clause, "due date‖ to mean the date by which the assessee is required as an employer to credit an employee's contribution to the employee's account in the relevant fund under any Act, rule, order or notification issued there-under or under any standing order, award, contract of service or otherwise. Section 43B specifies the list of deductions that are admissible under the Act only upon their actual payment. Employer's contribution is covered in clause (b) of section 43B. According to it, if any sum towards employer's contribution to any provident fund or superannuation fund or gratuity fund or any other fund for the welfare of the employees is actually paid by the assessee on or before the due date for furnishing the return of the income under sub-section (1) of section 139, assessee would be entitled to deduction under section 43B, and such deduction would be admissible for the accounting year. This provision does not cover employee contribution referred to in clause (va) of sub-section (1) of section 36 of the Act.

Though section 43B of the Act covers only employer ‘s contribution and does not cover employee contribution, some courts have applied the provision of section 43B on employee contribution as well. There is a distinction between employers 40contribution and employee ‘s contribution towards welfare fund. It may be noted that employee ‘s contribution towards welfare funds is a mechanism to ensure the compliance by the employers of the labour welfare laws. Hence, it needs to be stressed that the employer ‘s contribution towards welfare funds such as ESI and PF needs to be clearly distinguished from the employee ‘s contribution towards welfare funds. Employee's contribution is employee own money and the employer deposits this contribution on behalf of the employee in fiduciary capacity. By late deposit of employee contribution, the employers get unjustly enriched by keeping

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 19 of 21 the money belonging to the employees. Clause (va) of sub-section (1) of Section 36 of the Act was inserted to the Act vide Finance Act 1987 as a measure of penalizing employers who mis-utilize employee ‘s contributions.

Accordingly, in order to provide certainty, it is proposed to –(i) amend clause (va) of sub-section (1) of section 36 of the Act by inserting another explanation to the said clause to clarify that the provision of section 43B does not apply and deemed to never have been applied for the purposes of determining the ―due date‖ under this clause; and (ii) amend section 43B of the Act by inserting Explanation 5 to the said section to clarify that the provisions of the said section do not apply and deemed to never have been applied to a sum received by the assessee from any of his employees to which provisions of sub-clause (x) of clause (24) of section 2 applies. These amendments will take effect from 1st April 2021 and will accordingly apply to the assessment year 2021-22 and subsequent assessment years.

[Clauses 8 and 9]

28.

Further necessary amendment were also made under section 143 (1) of the act which are also explained as under:

Rationalisation of the provision relating to processing of returned income and issuance of notice under sub-section (2) of section 143 of the Act

The existing provisions of clause (a) of sub-section (1) of section 143 of the Act provides that at the time of processing of return of income made under section 139, or in response toa notice under sub-section (1) of section 142, the total income or loss shall be computed after making the adjustments specified in clauses (i) to (vi) therein.

It is proposed to amend the following provisions of sub-section (1) of section 143 of the Act, -

(i)Amend sub-clause (iv) of clause (a) of sub-section (1) of the section 143 of the Act, to allow for the adjustment on account of increase in income indicated in the audit report but not taken into account in computing the total income.(ii)Amend sub-clause (v) of clause (a) of sub-section (1) of the section 143 of the Act so as to give consequential effect to amendment carried out in section 80 AC vide Finance Act 2018.(iii)Amend the provisions of section 143 to reduce the time limit for sending intimation under sub-section (1) of section 143 of the Act from one year to nine months from the end of the financial year in which the return was furnished. Consequently, it is also proposed to reduce the time limit for issue of notice under sub-section (2)of section 143 of the Act from six months to three months from the end of the financial year in which the return is furnished. These amendments will take effect from 1st April 2021[Clause 34] 29. Thus, if one reads the memorandum explaining the provision in the Finance Bill 2021, it is apparent that Parliament would also like to introduce such an

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 20 of 21 amendment with effect from the assessment year 2021 – 22 and subsequent assessment years. The assessment years before us are 2019 – 20 and 2020 – 21. Therefore, it is apparent that for the impugned assessment year which are in appeal before us the adjustment made by the learned central processing Centre of disallowing the contribution of employees deposited beyond the due date prescribed under the respective act is not correct.

30.

The decision of the honourable Chhattisgarh High Court in case of Sanjay Kumar Sharma versus income tax officer (2025) 174 taxmann.com 592 (Chhattisgarh) is also covers the issue in favour of the assessee. The honourable Delhi High Court in principal Commissioner of income tax versus TV today network Ltd (2022) 141 taxmann.com 275 (Delhi) though with respect to the assessment year 2012 – 13 has categorically held that that the said amendment will take effect from 1 April 2021 and further the amendment itself is proposed to be made with effect from assessment year 2021 – 22, the decision of the honourable Delhi High Court also support the case of the assessee.

31.

When there are contradictory judgements of non jurisdictional high court the view in favour of the assessee is required to be taken. 32. In view of the above facts we hold that the adjustment made by the learned central processing Centre with respect to the deposit of employees' contribution to the credit of provident fund account beyond the due date specified under the respective act could not have been adjusted under section 143 (1) (a) of the act prior to assessment year 2021 – 22 and therefore the AO is directed to delete the adjustment to that extent. 33. As we have directed the ld AO to delete the additions, other issues are merely academic and are dismissed. 34. In the result both the appeals are allowed for statistical purposes.”

13.1 Respectfully, following the decision of this coordinate bench of the Tribunal, we held that the adjustment made by the CPC with respect to the deposit of employees contribution to the credit of provident fund account and ESI account beyond the due date specified under the respective Act could not have been made u/s 143(1)(a) of the Act prior to assessment year 2021-22 and therefore, the AO is directed to delete the adjustment to that extent.

ITA No.1770/Bang/2025 Ronald Belchar Fernandes, Mangaluru Page 21 of 21

14.

In the result, the appeal of the assessee is allowed.

Order pronounced in the open court on 22nd June, 2026

Sd/- Sd/- (Prashant Maharishi) (Keshav Dubey) Vice President Judicial Member

Bangalore, Dated 22nd June,2026. VG/SPS

Copy to:

1.

The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order

Asst. Registrar, ITAT, Bangalore.

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