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“Section 36(1)”

Section References (mined)Section 36Section 36(1)3,872 judgments

The decision most relied on for Section 36(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

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.

TRF Ltd. v. CIT
323 ITR 397 · 2010 · Supreme Court
714
citing judgments

For claiming deduction for bad debts under section 36(1)(vii) of the Income Tax Act, it is sufficient for the assessee to write off the debt as irrecoverable in its accounts, and it is not necessary to prove that the debt has actually become irrecoverable.

Judgments citing Section 36(1)

Circular Aircon Services Pvt. Ltd., Mumbai vs. ITO, Ward 12(1)(4), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2776/MUM/2023[2017-18]Status: DisposedITAT Mumbai29 Nov 2023AY 2017-18

Bench: Shri Aby T. Varkey, Jm & Shri S Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.2776/Mum/2023 (निर्धारण वर्ा / Assessment Year: 2017-18) Circular Aircon Services बिधम/ Ito, Ward-12(1)(4) 1St Floor, Income Tax Pvt. Ltd. Vs. 1, Mehta Industrial Estate, Office, New Marine Line, Jai Prakash Road No.2, Mumbai-400020. Goregaon (E), Mumbai- 400063. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaccc6387P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Ms. Neha Paranjpe Revenue By: Shri Satya Prakash Singh (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 20/11/2023 घोषणा की तारीख /Date Of Pronouncement: 29/11/2023 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/(Nfac), Delhi Dated 09.06.2023 For The Assessment Year 2017-18. 2. The Main Grievance Of The Assessee Is Against The Action Of The Ld. Cit(A)/Nfac Dismissing The Appeal Of The Assessee Exparte & Confirming The Disallowance Made By Cpc U/S 36(1)(Va) Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Ms. Neha ParanjpeFor Respondent: Shri Satya Prakash Singh (Sr. AR)
Section 143(1)Section 154Section 36(1)(v)Section 36(1)(va)Section 43B

wherein the assessee has given the details of the contribution received from employees for various funds as referred to in section 36(1)(va) of the Act wherein the assessee has given the list of the employees contribution along with the details of sum received from employees/Due date for payment/the ... Rs.13,74,758/- (and not Rs.22,32,820/-) and the balance portion i.e. Rs.8,58,062/- was the suo- motto disallowance made under section 36(1)(va) of the Act. The mistake happened (supra) because in the original ITR filed in Form no. 6, the assessee erroneously punched

B4S Solutions P.Ltd, New Delhi vs. DCIT, Central Circle-13, New Del;Hi

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 3047/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Nov 2023AY 2018-19

Bench: Shri G. S. Pannu, Hon’Ble Vice-A N D Shri Challa Nagendra Prasad

For Appellant: Advocate
Section 10(34)Section 143(1)Section 154

considered the rival submissions and perused the material available on record. The disallowance of employees’ contribution to PF/ESIC for breach of condition under Section 36(1)(va) is in controversy. 9.1 We notice at the outset that an opportunity was given via electronic platform of the deptt. for the proposed ... merit in such plea that the belated deposit of employees contributions to PF/ESIC governed under Section 36(1)(va) is also simultaneously amenable to deduction under Section 37(1) of the Act. In terms of the provision, Section 37(1) permits deduction of expenditure which is not in the nature

R K & Company Manpower P.Ltd, New Delhi vs. DCIT, Ciorcle-19(1), New Delbhi

In the result, appeals are allowed for statistical purposes

ITA 3014/DEL/2022[2020-21]Status: DisposedITAT Delhi29 Nov 2023AY 2020-21

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

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

were not paid/remitted within the due dates prescribed under the PE and ESI Act, disallowed such deduction in terms with Explanation 1 to section 36(1)(va) read with section 2(24)(x) of the Act. 4. Though, the assessee contested the aforesaid disallowances by filing appeals before the first ... Before us, it is the specific contention of the assessee that due date, as per section 36(1)(va) of the Act, should be the date on which salary was actually disbursed to the employees and not the date on which salary was due. In this context, learned counsel

R K & Company Manpower P.Ltd, New Delhi vs. DCIT, Circle-19(1), New Delhi

In the result, appeals are allowed for statistical purposes

ITA 3013/DEL/2022[2019-20]Status: DisposedITAT Delhi29 Nov 2023AY 2019-20

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

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

were not paid/remitted within the due dates prescribed under the PE and ESI Act, disallowed such deduction in terms with Explanation 1 to section 36(1)(va) read with section 2(24)(x) of the Act. 4. Though, the assessee contested the aforesaid disallowances by filing appeals before the first ... Before us, it is the specific contention of the assessee that due date, as per section 36(1)(va) of the Act, should be the date on which salary was actually disbursed to the employees and not the date on which salary was due. In this context, learned counsel

R K & Company Manpower P.Ltd, New Delhi vs. DCIT, Circle-20(2), New Delhi

In the result, appeals are allowed for statistical purposes

ITA 3012/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Nov 2023AY 2018-19

Bench: Shri Saktijit Dey, Vice- & Shri M. Balaganesh

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

were not paid/remitted within the due dates prescribed under the PE and ESI Act, disallowed such deduction in terms with Explanation 1 to section 36(1)(va) read with section 2(24)(x) of the Act. 4. Though, the assessee contested the aforesaid disallowances by filing appeals before the first ... Before us, it is the specific contention of the assessee that due date, as per section 36(1)(va) of the Act, should be the date on which salary was actually disbursed to the employees and not the date on which salary was due. In this context, learned counsel

Bhim Singh, Gurgon vs. DCIT, Circle-1, Gurgaon

In the result, both the appeals of the assessee are dismissed

ITA 2979/DEL/2022[2019--20]Status: DisposedITAT Delhi29 Nov 2023

Bench: Shri G. S. Pannu, Hon’Ble Vice-A N D Shri Challa Nagendra Prasad

For Appellant: Shri Anuj Tiwari
Section 139(1)Section 143(1)Section 2(24)(x)Section 36Section 36(1)(va)Section 43B

36(1)(va) of the Act on account of contributions received from employees for funds referred in Section 36(1)(va) of the Act. 6. That the CIT(A)/CPC has failed to appreciate that the Finance Act, 2021 amendment is prospective in nature and are applicable from ... same do not justify the addition/ disallowance made.” 3. The issue of whether the employees’ contribution to PF/ESI is allowable expenditure under section 36(1)(va) of the Act if it is paid beyond the due date specified under PF/ESI Act came up befor the Hon’ble Supreme Court

Bhim Singh, Gurgaon vs. DCIT, Circle-1, Gurgon

In the result, both the appeals of the assessee are dismissed

ITA 2978/DEL/2022[2018-19]Status: DisposedITAT Delhi29 Nov 2023AY 2018-19

Bench: Shri G. S. Pannu, Hon’Ble Vice-A N D Shri Challa Nagendra Prasad

For Appellant: Shri Anuj Tiwari
Section 139(1)Section 143(1)Section 2(24)(x)Section 36Section 36(1)(va)Section 43B

36(1)(va) of the Act on account of contributions received from employees for funds referred in Section 36(1)(va) of the Act. 6. That the CIT(A)/CPC has failed to appreciate that the Finance Act, 2021 amendment is prospective in nature and are applicable from ... same do not justify the addition/ disallowance made.” 3. The issue of whether the employees’ contribution to PF/ESI is allowable expenditure under section 36(1)(va) of the Act if it is paid beyond the due date specified under PF/ESI Act came up befor the Hon’ble Supreme Court

DCIT, Circle-3(1), Gurgaon vs. Posco Engineering and Construction India Private Limited, Gurgaon

In the result, appeal of the Revenue is dismissed

ITA 1137/DEL/2022[2017-18]Status: DisposedITAT Delhi29 Nov 2023AY 2017-18

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2017-18

For Appellant: Shri G S Kohli, CAFor Respondent: Shri P N Barnwal, CIT(DR)
Section 36(1)Section 68

advances be not disallowed under Page 3 of 9 ITA No.-1137/Del/2022 & CO No. 196/Del/2022 Posco Engineering & Construction India Pvt. Ltd. section 36(1)(iii) of the Act. According to the Ld. AO, the assessee company’s funds comprise of interest bearing funds as well as non-interest bearing ... have not been proved by the assessee that they are for business purpose. Accordingly, the Ld. AO disallowed Rs. 31,17,561/- under section 36(1)(iii) of the Act, observing in para 3.3. of the Assessment Order as under: “3.3 Since these advances of Rs.12511667/- to "others" were given

Addl. CIT, Special Range- 7, New Delhi vs. Ptc India Financial Services Ltd, New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7433/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance of Rs. 1,76,16,528/- is illegal ... grossly erred on facts and in law in upholding the addition/disallowance made by the AO of Rs 2,89,99,437/- under section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises

Ptc India Financial Services Ltd., New Delhi vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 7273/DEL/2017[2014-15]Status: DisposedITAT Delhi29 Nov 2023AY 2014-15

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance of Rs. 1,76,16,528/- is illegal ... grossly erred on facts and in law in upholding the addition/disallowance made by the AO of Rs 2,89,99,437/- under section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises

ACIT, New Delhi vs. M/S. Ptc India Financial Services Ltd., New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2175/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance of Rs. 1,76,16,528/- is illegal ... grossly erred on facts and in law in upholding the addition/disallowance made by the AO of Rs 2,89,99,437/- under section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises

M/S. Ptc India Financial Services Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessee for AY 2013-14 and 2014-15

ITA 2162/DEL/2017[2013-14]Status: DisposedITAT Delhi29 Nov 2023AY 2013-14

Bench: Shri N.K. Billaiya & Ms. Astha Chandraasstt. Year 2013-14 & Asstt. Year 2014-15

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 234BSection 36(1)(viii)Section 37

facts and in law in restoring the matter to the Assessment Officer and not allowing the deduction claimed by the Assessee under Section 36(1)(viii) of the Income Tax Act 1961. 7. That the disallowance of Rs. 1,76,16,528/- is illegal ... grossly erred on facts and in law in upholding the addition/disallowance made by the AO of Rs 2,89,99,437/- under section 36(1)(viii). This addition may kindly be deleted. 6. That the disallowances made/upheld and the observations made are unjust, unlawful and based on mere surmises

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Vvr Engineering, Visakhapatnam

In the result, appeal of the Revenue is dismissed

ITA 236/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam29 Nov 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Sri Mdhukar Aves, Sr. AR
Section 250Section 36(1)(va)Section 43B

Circular No. 22/2015 dated 17/12/2015 wherein the claim of deduction relating to employee’s contribution to welfare funds which are governed by section 36(1)(va) of the Act. 4. The Ld. CIT(A) erred in not considering the amendment had been brought in Finance Act, 2021 that the delayed

Biltech Engineers Pvt Ltd., Bhilai, Durg vs. Assistant Commissioner of Income Tax-1(1), Bhilai, Durg

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 274/RPR/2023[2015-16]Status: DisposedITAT Raipur29 Nov 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.274/Rpr/2023 "नधा"रण वष" / Assessment Years : 2015-16 Biltech Engineers Private Limited 4Th Floor Surya Treasure Island Mall, Junwani Road, Smriti Nagar, Bhilai (C.G.) Pan : Aaccb2418A .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri R.B. Doshi, C.AFor Respondent: Shri Satya Prakash Sharma, Sr.DR
Section 143(3)Section 28Section 36(1)(vii)Section 37

appellant failed to prove that amount paid to developer as advance for booking commercial space was in the ordinary course of business — section 36(1)(vii) r.w.s. 28(i). 2. Elite International Pvt. Ltd. vs. ACIT 83 taxmann.com 213 (Mum-ITAT) (2017) — Assessee could not produce any evidence to show

ACIT-3(1)(1), Mumbai vs. Rustomjee Realty Pvt. Ltd., Mumbai

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

ITA 1585/MUM/2023[2020-21]Status: DisposedITAT Mumbai28 Nov 2023AY 2020-21

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Naresh KumarFor Respondent: Smt. Sanyogita Nagpal
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH

Ganesh Gupta, Wani vs. Principal Commissioner of Income Tax-2, Nagpur

Appeal of the assessee is allowed

ITA 54/NAG/2021[2016-17]Status: DisposedITAT Nagpur28 Nov 2023AY 2016-17

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripote

For Appellant: Shri Mahavir Atal, C.AFor Respondent: Shri Kailash Kanojiya, Sr. DR CIT
Section 142Section 143(3)Section 263Section 36(1)(iii)

free funds generated or available with the company. Then, the borrowed capital in hand in that case and interest expenditure was deductible under Section 36(1)(iii) of the I.T. Act, 1961. The Tribunal held that the interest free fund available to the assessee is sufficient to meet its investment

M/S. Jai Enterprises, Raipur vs. Assistant Director of Income Tax, CPC, Bangaluru

In the result the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 107/RPR/2021[2019-20]Status: DisposedITAT Raipur28 Nov 2023AY 2019-20

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am (Ita No.107/Rpr/2021) (Assessment Year: 2019-20)

For Appellant: Shri Nikhilesh Begani, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

Learns Asst. Director of Income Tax (CPC) ("the Ld. CPC") in making the addition/disallowance of Rs.39,80,729/- Invoking the provisions of section 36(1)(va) of the Act on account of delayed deposit of employees' contribution to Employees Provident Fund (EPF) & Employees State Insurance Corporation (ESIC) beyond ... Jurisdictional Tribunal. (d)That the Ld. CIT(A) has grossly erred in placing reliance on & erroneously applying the amended provisions of sections 36(1)(va) & 43B of the Act as inserted vide the Finance Act, 2021 to the assessment year under reference which were expressly intended to be applied prospectively

M/S Ashok Engineering Works, Korba vs. Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur

In the result, appeal of the assessee in ITA No

ITA 54/RPR/2022[2018-19]Status: DisposedITAT Raipur24 Nov 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 53 & 54/Rpr/2022 "नधा"रण वष" / Assessment Years : 2017-18 & 2018-19 M/S. Ashoka Engineering Works, Lig-51, Sada Colony, Jamnipali, Korba (C.G.)-495 450 Pan : Aaafw5581G .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Y.K Mishra, AdvocateFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(1)Section 154Section 36(1)(va)

Commissioner of Income Tax-I, Civil Appeal No.2833 of 2016 dated 12.10.2022, wherein it was held that as per the mandate of Section 36(1)(va) r.w.s. 2(24)(x) of the Act, the delayed deposit of employee’s share of contribution towards labour welfare funds, viz. Employee’s Provident ... funds, viz. Employee’s Provident fund (EPF) and Employee’s State Insurance (ESI) is liable to be disallowed as per the mandate of Section 36(1)(va) r.w.s. 2(24)(x) of the Act. As pointed out by the Ld. DR, and, rightly so, the order of the Tribunal

M/S Ashoka Engineering Works, Korba vs. Deputy Commissioner of Income Tax, Circle-1(1), Bilaspur

In the result, appeal of the assessee in ITA No

ITA 53/RPR/2022[2017-18]Status: DisposedITAT Raipur24 Nov 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos. 53 & 54/Rpr/2022 "नधा"रण वष" / Assessment Years : 2017-18 & 2018-19 M/S. Ashoka Engineering Works, Lig-51, Sada Colony, Jamnipali, Korba (C.G.)-495 450 Pan : Aaafw5581G .......अपीलाथ" / Appellant बनाम / V/S. The Deputy Commissioner Of Income Tax, Circle-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Shri Y.K Mishra, AdvocateFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(1)Section 154Section 36(1)(va)

Commissioner of Income Tax-I, Civil Appeal No.2833 of 2016 dated 12.10.2022, wherein it was held that as per the mandate of Section 36(1)(va) r.w.s. 2(24)(x) of the Act, the delayed deposit of employee’s share of contribution towards labour welfare funds, viz. Employee’s Provident ... funds, viz. Employee’s Provident fund (EPF) and Employee’s State Insurance (ESI) is liable to be disallowed as per the mandate of Section 36(1)(va) r.w.s. 2(24)(x) of the Act. As pointed out by the Ld. DR, and, rightly so, the order of the Tribunal

Pradeep Kumar Dhurve, Durg vs. Deputy Commissioner of Income-Tax, Circle 1(1), Bhilai

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 302/RPR/2023[2018-19]Status: DisposedITAT Raipur23 Nov 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 302/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 Pradeep Kumar Dhurve Near Pawan Kirana Store, Sangram Chowk, Prem Nagar, Sikola Bhata, Durg (C.G.)-491 001 Pan : Aanpd6067H

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

before the due date of filing return specified as 139(1) of the Income-tax Act, 1961 by invoking provision of section 36(1)(va). Disallowance out of employees contribution to Rs.3,41,636/- "Employee State Insurance Corporation (ESIC) paid after the due date specified in the "Employment State Insurance ... before the due date of filing return specified u/s 139(1) of the Income-tax Act, 1961 by invoking provision of section 36(1)(va). Disallowance out of Service Tax payable before Rs.7,66,013/- the due dates specified in the relevant Acts and before the due date of filing