SIS PROSEGUR HOLDINGS PRIVATE LIMITED,PATNA vs. ITO WARD 2(1), PATNA, PATNA

ITA 143/PAT/2026Status: DisposedITAT Patna02 July 2026AY 2020-216 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal restored the issue to the Assessing Officer to ascertain the due date for remittance of employee PF/ESI contributions. The AO is directed to decide the issue afresh after providing an opportunity to the assessee.

What were the facts?

The assessee filed a return declaring NIL income. A rectification order disallowed Rs. 1,63,64,910/- for late deposit of employee contribution to PF/ESI. The CIT(A) dismissed the assessee's appeal, relying on the Supreme Court judgment in Checkmate Services Private Limited.

What were the issues?

Whether the disallowance for late deposit of employee PF/ESI contributions is justified, and the methodology for calculating the delay in remittance.

Which sections of the Income-tax Act were involved?

Section 36(1)(va),Section 154,Section 250,Section 37(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH

Before: SHRI LAXMI PRASAD SAHU & SHRI YOGESH KUAMR U.S.

For Appellant: Ms. Aabgina Chisthi, AR
For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 30.06.2026Pronounced: 02.07.2026

PER YOGESH KUMAR U.S., JUDICIAL MEMBER:

This Appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeal) [“the Ld. CIT(A)”, for short], dated 28.01.2026 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the Assessment Year 2020-21. 2. Brief facts of the case are that, Assessee filed return of income declaring NIL income. A rectification u/s 154 of the Act was issued by the CPC, Bangalore on 20.07.2022 by disallowing a sum of Rs.1,63,64,910/-. Aggrieved by the said order of the CPC, Bangalore, SIS Prosegur Holdings Private Limited; A.Y: 2020-21 Assessee preferred an Appeal before the

The order continues below.

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