How many judgments cite CIT v. Gujarat State Road Transport Corporation?

1,158 judgments on BharatTax cite CIT v. Gujarat State Road Transport Corporation (366 ITR 170), spanning 2015 to 2025.

Which sections of the Income Tax Act does CIT v. Gujarat State Road Transport Corporation come up under?

It is most often cited in judgments turning on Section 139(1), Section 143(3), Section 2(24)(x), Section 250, Section 36(1)(va), Section 1961.

CIT v. Gujarat State Road Transport Corporation

366 ITR 170High Court2014#38 most cited

What is CIT v. Gujarat State Road Transport Corporation authority for?

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

1,158

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v. Gujarat State Road Transport Corporation · 366 ITR 170 · Section 36(1)(va) · Section 2(24)(x) · employees contribution to provident fund · delayed deposit of PF · disallowance of employee contribution · due date for deposit · welfare fund contributions · EPF Act due date · Checkmate Services

Sections most often in play

Section 139(1)Section 143(3)Section 2(24)(x)Section 250 Section 36(1)(va)Section 1961 Section 40A(7)Section 43B

Issues it is cited on

employees contribution to pf section 2(24)(x)section 36(1)(va)section 2(24)section 43b section 43 section 36 section 36(1)section 139(1)section 139 section 143(1)section 13

Judgments citing CIT v. Gujarat State Road Transport Corporation

Akash Fashion Prints Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(1)(4), Ahmedabad

In the result, ITA No. 517/Ahd/2017 is also partly allowed in the terms indicated above

ITA 517/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad01 Jul 2019AY 2013-14

Section 143(3)Section 2(24)

…so held now and the addition made be deleted.” 9. Learned representatives fairly agree that the issue is covered, in favour of the revenue, by Hon’ble jurisdictional High Court’s judgment in the case of CIT vs. Gujarat State Road Transport Corp. Ltd [(2014) 366 ITR 170 (Guj)]. We, therefore, approve the conclusion arrived at by the CIT(A) and decline to interfere in the matter. 10. Ground no.2 is dismissed. 11. In ground no. 3, the appellant has raised the following grievance:- “3. The learned CIT(A) grossly erred in law and on facts in confirming disallowance of Rs.19,26,111/- out of interest expenses incur…

Akash Fashion Prints Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

In the result, ITA No. 517/Ahd/2017 is also partly allowed in the terms indicated above

ITA 516/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad01 Jul 2019AY 2012-13

Section 143(3)Section 2(24)

Bright Autoplast Ltd., Ahmedabad vs. Asstt. CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the Revenue is partly allowed for statistical purposes

ITA 1990/AHD/2015[2008-09]Status: DisposedITAT Ahmedabad28 Jun 2019AY 2008-09

Bench: Shri Mahavir Prasad & Shri Waseem Ahmedsl.

For Appellant: Ms. Sonia Kumar Sr.DRFor Respondent: Shri Milin Mehta, AR

Section 234BSection 234CSection 234DSection 271(1)(c)Section 35D

…ade by the AO u/s 36(1)(va) r.w.s. 2(24)(x) of the Act. The Ld. CIT-A subsequently confirmed the view taken by the AO. The Ld. AR before us has not challenged the proposition laid down by the Hon’ble Gujarat High Court in the case of CIT Vs. GSRTC reported in 366 ITR 170, wherein it was held as under: “In view of the above and for the reasons stated above, and considering section 36(1)(va) of the Income Tax Act, 1961 read with sub-clause (x) of clause 24 of section 2, it is held that with respect to the sum received by the assessee from any ITA No.1990/Ahd/2015 & ten others Bright Autoplast Ltd. vs. ACIT Circle-…

The DCIT, Circle-4(1)(1), Ahmedabad vs. M/S. Suzlon Energy Ltd., Ahmedabad

In the result, appeals of the assessee are allowed for statistical purposes

ITA 619/AHD/2017[2011-12]Status: DisposedITAT Ahmedabad25 Jun 2019AY 2011-12

Bench: Shri Pramod Kumar&Smt. Madhumita Royआयकरअपीलसं.Ita No. 619/Ahd/2017 & C.O. No. 77/Ahd/2017 "नधा"रणवष"/Asstt. Year: 2011-12

For Appellant: ShriJamesKurian, Sr. DRFor Respondent: ShriTusharHemani, CA

Section 115JSection 143(3)Section 14a

…n of the said judgment is as follows:- “3. Learned representatives fairly agree that the aforesaid issue is squarely covered against the assessee by Hon'ble jurisdictional High Court's judgment in the case of CIT vs. Gujarat State Road Transport Corporation, 366 ITR 170 (Guj.), wherein it is categorically held that in the case of delayed deposit of employees' contribution to PF, the same will not be deductable in computing income under section 28 of the Act. The law so laid down by the Hon'ble jurisdictional High Court is binding on us. The mere fact that an appeal against the said decision is pending before the…

Deputy Commissioner of Income Tax Circle-5(1)(2), Bangalore vs. M/S Page Industries Limited, Bangalore

In the result, the appeal by the revenue is partly allowed for statistical purpose

ITA 1209/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Jun 2019AY 2014-15

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2014-15

For Appellant: Dr. Shankar Prasad, Addl.CIT(DR)(ITAT), BengaluruFor Respondent: Smt. Suman Lunkar, CA

Section 115JSection 139(1)Section 43BSection 80J

…igh Court of Karnataka in the case of CIT v. Sabari Industries [2008] 298 ITR 141 (Kar). 3. The ld. DR, however, placed reliance on a contrary decision rendered by the Hon’ble Gujarat High Court in the case of CIT v. Gujarat State Road Transport Corporation, 366 ITR 170 (Guj). 4. The decision of the Hon’ble High Court of Karnataka which is the jurisdictional High Court is to be followed by the Tribunal. Consequently, we find no merit in the relevant ground No.1 of appeal of the revenue. ITA No.1209/Bang/2018. Page 3 of 6 5. As far as ground No. 2 is concerned, it pertains to deduction u/s. 80JJAA of the Act…

Sanghvi Forging & Engg.Ltd., Baroda vs. The DCIT, Circle-2(1)(1), Baroda

In the result the appeal of the assessee is allowed

ITA 2307/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad23 May 2019AY 2013-14

For Appellant: Ms. Urvashi Shodhan, A.RFor Respondent: Smt. Smiti Samant, Sr.DR

Section 2(24)(x)Section 234ASection 271(1)Section 36Section 36(1)(va)

…should be allowed as a deduction under section 43B of the Act. 3.1 However the learned CIT (A) disregarded the contention of the assessee after having a reliance on the judgment of Hon’ble Jurisdictional High Court in the case of CIT versus GSRTC reported in 366 ITR 170. Accordingly, the learned CIT (A) confirmed the order of the AO. 4. Being aggrieved by the order of the learned CIT (A) the assessee is in appeal before us. The learned AR before us submitted that the payment towards the employee's provident fund was made after the due date but within in the grace period as specified under the PF Act in all the…

A. Menarini India Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-1(1)(1), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 2199/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad23 May 2019AY 2014-15

Bench: Shri Mahavir Prasad&Shri Amarjit Singhआयकर अपील सं./I.T.A. No. 2199/Ahd/2017 ("नधा"रण वष" / Assessment Year:2014-15) A. Menarini India Pvt. Ltd. Dcit बनाम/ Circle- 1(1)(1), A-101, Shapath Iv, Vs. Ahmedabad Near Karnavati Club, S.G. Highway, Ahmedabad- 380015 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaa Ci9 822 K .. (अपीलाथ"/Appellant) (""यथ" / Respondent)

For Appellant: Kamlesh Makwona, Sr. DRFor Respondent: 10/05/2019

Section 139(1)Section 143(2)Section 143(3)Section 36(1)(v)Section 36(1)(va)Section 43B

…employees’ contribution to the Provident and ESIC. The Ld. CIT(A) has dismissed the appeal of the assessee after placing reliance on the ITA NO. 2199/AHD/2017 A.Y. 2014-15 decision of Hon’ble Gujarat High Court in the case of State Road Transport Corporation 366 ITR 170. The relevant part of the decision of the Ld. CIT(A) is reproduced as under:- “3.3. I have carefully considered Assessment order and submission filed by the Appellant. I have carefully considered the assessment order and the submission filed by the appellant. The Assessing Officer has observed that appellant has failed to deposit employees’ cont…

Vidres India Ceramics Pvt. Ltd., Ahmedabad vs. The Dy. CIT, Circle-4(1)(2), Ahmedabad

In the result, assessee’s appeal is allowed

ITA 2521/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad17 May 2019AY 2013-14

Bench: Shri Pramod Kumar & Ms. Madhumita Roy

For Appellant: Shri A. C. Shah, A.RFor Respondent: Shri S. K. Dev, Sr. D.R

Section 143(1)Section 143(2)Section 143(3)Section 2(24)(x)Section 36(1)(iii)Section 36(1)(va)Section 36(1)(vii)

…as the assessee has paid such contribution before the end of accounting year for Vidres India Ceramics Pvt. Ltd. vs DCIT Asst.Year –2013-14 all months except for the month of February and March and the Gujarat High Court decision in the case of CIT V/s. GSRTC 366 ITR 170 is not applicable on the facts of the case. 2. The learned CIT(A) has erred in confirming addition of provision for bad and doubtful debts of Rs. 5,23,625/- under Section 36(1)(vii) in as much as the assessee is covered by SC decision in the case of CIT vs. Vijya Bank 323 ITR 166 (SC).” 2. Ground No.1 : At the time of hearing of the instant appe…

Shri Khodiyar Fabricators and Technologies Pvt. Ltd., Surat vs. The Income Tax Officer, Ward-2(1)(2), Surat

In the result, the appeal of the assessee is dismissed

ITA 1128/AHD/2017[2013-14]Status: DisposedITAT Surat15 May 2019AY 2013-14

Bench: Shri Bhavnesh Saini & Shri O. P. Meena

Section 2Section 28Section 36(1)(va)Section 43B

…n the ground that that same were paid beyond during date prescribed under the respective statutes. In doing so the CIT (A) has placed reliance on the decision of Hon’ble Gujarat High Court in the case of CIT v. Gujarat State Road Transport Corporation [2014] 366 ITR 170 (Guj) : 223 Taxman 398 : [2014] 41 taxmann.com 100 (2014) (1) TML 502 -Guj-HC. 5. Being, aggrieved the assessee filed this appeal before the Tribunal. None appeared for the assessee. 6. The ld. Sr. D.R. submits that the issue is squarely covered against the assessee by Hon’ble jurisdictional High Court’s judgment in the case of CIT vs. Gujar…

The Dy. CIT., Circle-1(1)(1), Ahmedabad vs. M/S. Astral Polytechnik Ltd., Ahmedabad

In the result, assessee’s CO is dismissed

ITA 2235/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad06 May 2019AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri Vinod Tanwani, Sr. D.RFor Respondent: Ms. Ira Kapoor, A.R

Section 143Section 143(2)Section 143(3)Section 14ASection 80I

…wance cannot be made. 7.4 On careful consideration of observation of Assessing Officer and contention of appellant, I observe that entire issue is covered against appellant by decision of Hon'ble Gujarat High court in case of State Road Transport Corporation (366 ITR 170) wherein it is held as under : "Section 43B, read with section 36(1)(va) of the Income-tax Act, 1961 -Business disallowance - Certain deductions to be allowed on actual payment (Employees contribution) - Whether where an employer has not credited sum received by it as employees' contribution to employees' account in relevant fund on or before due…

Shri Purshottam B. Pitroda, Ahmedabad vs. The ACIT, Circle-12, Ahmedabad

Appeal is partly allowed

ITA 567/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad03 May 2019AY 2012-13

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri A. C. Shah & Bhaumil K. Patel, A.RFor Respondent: Shri Ranjan Kumar Singh, Sr.D. R

Section 143(3)Section 36Section 36(1)(iii)

…ound relates to confirming the ESI & PF with regard to contribution by employee of Rs.1,89,774/- u/s 36(1)(va) of the Act on the ground that the issue is covered by the Jurisdictional High Court in the judgment passed in the matter of CIT-vs-GSRTC reported in 366 ITR 170. It is a settled principle of law that to be eligible for deduction u/s 36(1)(va) of the Act, the assessee has to pay the amount of employee’s contribution towards PF/ESI to the Government account within the due date specified in the concerned Act. In this particular case, the assessee has failed to credit the same within the stipulated time and…

Shri Purshottam B. Pitroda, Ahmedabad vs. The ACIT, Circle-12, Ahmedabad

Appeal is partly allowed

ITA 566/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad03 May 2019AY 2011-12

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Appellant: Shri A. C. Shah & Bhaumil K. Patel, A.RFor Respondent: Shri Ranjan Kumar Singh, Sr.D. R

Section 143(3)Section 36Section 36(1)(iii)

M/S. Shree Padmavati Engineers (I) Pvt.Ltd., Mumbai vs. The Additional Commissioner of Income Tax, Bharuch Range, Bharuch

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

ITA 1815/AHD/2016[2011-12]Status: DisposedITAT Surat02 May 2019AY 2011-12

Bench: Shri H.S. Sidhu & Shri O. P. Meena

…tutes. 10. Being aggrieved, the assessee filed an appeal before the ld. CIT (A). The ld. CIT (A) has confirmed the said disallowance by following the judgement of Hon’ble Gujarat High Court in the case of CIT v. Gujarat State Road Transport Corporation [2014] 366 ITR 170 (Guj Shree Padamavati Engineering (I) Pvt. Ltd. v. Addl. CIT Bharuch /I.T.A. No. 1815/AHD/2016/A.Y.11-12 Page 6 of 7 11. Being, aggrieved the assessee filed this appeal before the Tribunal. The learned counsel for the assessee submitted that the assessee belongs to Mumbai hence, decision of Hon’ble Gujarat High Court is not applicable. 12. Au co…

Sh. Suraj Prakash, Amrtitsar vs. Income Tax Officer, Ward - 5(5), Amritsar

In the result, the assessee’s appeal is partly allowed

ITA 638/ASR/2017[2014-15]Status: DisposedITAT Amritsar30 Apr 2019AY 2014-15

Bench: Sh. Sanjay Arorai.T.A. No. 638/Asr/2017 Assessment Year: 2014-15

For Appellant: Sh. K. R. Jain (Adv.)For Respondent: Sh. Charan Dass (D.R.)

Section 143(3)Section 2(24)(vi)

…les framed there-under, being the 20th and 21st of the subsequent month for which the employees’ deduction by the employer qua EPF and ESI respectively for a particular calendar month, placing reliance on CIT v. Gujarat State Road Transport Corporation [2014] 366 ITR 170 (Guj). 7. I have heard the parties. The facts are not in dispute; the payment in each case has been made by the due date of filing the return for the relevant year u/s. 139(1), which stands extended upto 30.11.2014 (vide CBDT notification dated 26/9/2014). The Revenue’s case is unexceptional. So, however, the Hon’ble jurisdictional High Court ha…

Ocean Agro (India) Ltd., Ahmedabad vs. DCIT, Circle-3(1)(2), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 179/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad24 Apr 2019AY 2014-15

Bench: Shri Rajpal Yadav & Shri Amarjit Singhआयकर अपील सं./ Ita No.179/Ahd/2018 "नधा"रण वष"/Asstt. Year: 2014-15 Ocean Agro (India) Ltd. Vs. Dcit, Cir.3(1)(2) A/207, Oxford Avenue Ahmedabad. Ashram Road Ahmedabad 380 009. Pan : Aaaco 1849 A अपीलाथ"/ (Appellant) "त् यथ"/ (Respondent)

For Appellant: Ira Kapoor, ARFor Respondent: Shri Dinesh Singh, Sr.DR

Section 2(24)(x)Section 36(1)(va)Section 43B

…within the due date prescribed under respective laws. The ld.AO with the aid of section 2(24)(x) r.w.s. 36(1)(va) of the Income Tax Act and following judgment of Hon’ble Jurisdictional High Court in the case of CIT v. Gujarat State Road Transport Corporation 366 ITR 170 (Guj) disallowed the claim of the assessee. The action of the AO was confirmed by the ld.CIT(A). Assessee is in further appeal before us. 4. After hearing both the sides on the issue, we find that this issue has been settled by the Hon’ble jurisdictional High Court in two decisions, viz. in the case of Gujarat State Road Transport Corporation Lt…

Aspen Infrastructure Limited (Formerly Synefra Engineering & Const. Ltd), Ahmedabad vs. DCIT, Circle-4(1) (1), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 1726/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad08 Apr 2019AY 2013-14

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 1726/Ahd/2017 "नधा"रण वष"/Assessment Year: 2017 Aspen Infrastructures Ltd. Dcit, Cir.4(1)(1) (Formerly Synefra Engineering & Vs Ahmedabad. Construction Ltd.) 5, Shrimali Society Nr. Shri Krishna Complex Narangpura, Ahmedabad 380009. Pan : Aaccs 6871 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri P.B. Parmar, Ar Revenue By : Shri G.C. Daxini, Sr.Dr

For Appellant: Shri P.B. Parmar, ARFor Respondent: Shri G.C. Daxini, Sr.DR

Section 36(1)(va)

…hin due date provided in the PF and ESI Acts, therefore, he disallowed it. On appeal, the ld.CIT(A) has confirmed the disallowance by following decision of Hon’ble jurisdictional High Court in the case of CIT Vs. Gujarat State Road Transport Corporation Ltd., 366 ITR 170. The ld.counsel for the assessee contended before us that the issue be remitted to the AO for verification of the payments. He made reference to the decision of ITAT in the case of Suzlon Energy Ltd. Vs. DCIT, Ahmedabad. 5. On consideration of the above facts, we find that the details of payments were already noticed by the AO in para-4.1 and we…

M/S. Belgium Glass & Ceramics Pvt. Ltd., Baroda vs. The DCIT, Circle -1(1) (1), Vadodara

In the result, appeal of the assessee is dismissed

ITA 1725/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad08 Apr 2019AY 2013-14

Bench: Shri Rajpal Yadav & Shri Waseem Ahmedआयकर अपील सं./ Ita No. 1725/Ahd/2017 "नधा"रण वष"/Assessment Year: 2013-14

For Appellant: Shri Mukund Baxi, ARFor Respondent: Shri G.C.Daxini, Sr.DR

Section 143(2)Section 2(24)(x)Section 36(1)(va)Section 43B

…nted out by the auditors of the company in its report. The ld.AO with the aid of section 2(24)(x) r.w.s. 36(1)(va) of the Income Tax Act and following judgment of Hon’ble Jurisdictional High Court in the case of CIT v. Gujarat State Road Transport Corporation 366 ITR 170 (Guj) disallowed the claim of the assessee. The action of the AO was confirmed by the ld.CIT(A). Assessee is in further appeal before us. 4. After hearing both the sides on the issue, we find that this issue has been settled by the Hon’ble jurisdictional High Court in two occasions, viz. in the case of Gujarat State Road Transport Corporation Lt…

The Dy. Commissioner of Income Tax, Circle-1(1)(1), Ahmedabad vs. M/S. Adani Logistics Ltd., Ahmedabad

In the result, appeal of the Revenue is dismissed

ITA 2007/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad29 Mar 2019AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad)

For Appellant: Shri Lalit P. Jain, Sr. D.RFor Respondent: Shri S.N. Soparkar & Vartik Chokshi, A.R

Section 14ASection 40Section 41(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “C” BENCH (BEFORE SHRI PRADIP KUMAR KEDIA, ACCOUNTANT MEMBER & SHRI MAHAVIR PRASAD, JUDICIAL MEMBER) ITA. No: 2007/Ahd/2016 & C.O. No. 158/Ahd/16 (Assessment Year: 2012-13) DCIT, Circle-1(1)(1), V/S Adani Logistics Ltd. Adani Ahmedabad House Nr. Mithakali Circle Navrangpura, Ahmedabad Adani Logistics Ltd. Adani V/S House Nr. Mithakali Circle DCIT, Circle-1(1)(1), Navrangpura, Ahmedabad Ahmedabad (Appellant) (Respondent) PAN: AABCI4157J Appellant by : Shri Lalit P. Jain, Sr. D.R. Respondent by: Shri S.N. Soparkar & Vartik Chokshi, A.R. (आदेश)/ORDER Date…

Aditya Medisales Limited, Baroda vs. The Dy.CIT, Circle-1(1), Baroda

In the result, appeal of the assessee is partly allowed whereas

ITA 3049/AHD/2014[2008-09]Status: DisposedITAT Ahmedabad29 Mar 2019AY 2008-09

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr

For Appellant: Shri S. N. Soparkar, A.RFor Respondent: Shri Anshu Prakash, CITD.R

Section 115JSection 14ASection 43B

…count of delayed payments of employees’ contribution towards provident fund of Rs.54,775/-. 6.1 The aforesaid issue has been decided against the assessee by the Hon’ble Gujarat High Court in the case of CIT vs. Gujarat State Road Transport Corporation [2014] 366 ITR 170 (Guj). Therefore, the grievance of the assessee is answered in negative and against the assessee. 6.2 In the result, Ground No.4 is accordingly dismissed. 7. Ground No.5 concerns adjustment to the book profit computed under s.115JB of the Act towards provision of wealth tax of Rs.34,940/-. 7.1 The assessee seeks to claim that wealth tax is not…

Shri Ram Fire Works Pvt. Ltd., Rajkot vs. Income Tax Officer, Ward-2 (1) (4), Rajkot

Appeal of the Assessee is dismissed

ITA 390/RJT/2018[2015-16]Status: DisposedITAT Rajkot20 Mar 2019AY 2015-16

Bench: Shri Mahavir Prasad & Shri Waseem Ahmed)

For Appellant: Shri Ranjit D. Lalchandani, A.RFor Respondent: Shri B.R. Mishra, Sr. D.R

Section 139(1)Section 36(1)(va)Section 43B

…re paid to the government beyond the due date the same were disallowable. Thereafter in appeal ld. CIT(A) confirmed action of the A.O. 3. Before us, ld. A.R. fairly conceded that this case is against the assessee the Hon’ble High Court in the matter of GSRTC 366 ITR 170 wherein it is held: "Section 43B, read with section 36(1)(va) of the Income-tax Act, 1961 - Business disallowance - Certain deductions to be allowed on actual payment (Employees contribution) - Whether where an employer has not credited sum received by it as employees' contribution to employees' account in relevant fund on or before due date as p…