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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)

Twopiradian Infotech Private Limited, Kolkata vs. ITO Ward 2(1)-Kol, Kolkata

Appeals are allowed for statistical purposes

ITA 246/KOL/2025[2021-22]Status: DisposedITAT Kolkata04 Aug 2025AY 2021-22

Bench: the Joint Commissioner (Appeals) or the Commissioner of Income Tax (Appeals) under Section 246A of the Income Tax Act, 1961, on 13/02/2024, though belatedly, vide e-Filing Acknowledgement Number: 110773970130224 for the Assessment Year 2021-22 belatedly on the grounds explained WAR the Statement of Facts and Grounds of Appeal.

Section 245Section 246ASection 250Section 253

ground of belated filing of Appeal, is unlawful and in violation of principles of natural justice. 2. The disallowance of expenditure pursuant to Section 36(1)(va) of the Income Tax Act, 1961, amounting to 29,84,656/- based only on the Audit Report under Section 44AB ... specified under the Employees' Provident Funds and Miscellaneous Provisions Act, 1952, vis-à-vis Employees share of contribution as dealt with by Section 36(1)(va) of the Act, as detailed below: Though, admittedly the Assessee has delayed in depositing the contributions under the funds as specified under Section 36

Twopiradian Infotech Private Limited, Kolkata vs. ITO Ward 2(1), Kolkata

Appeals are allowed for statistical purposes

ITA 245/KOL/2025[2020-21]Status: DisposedITAT Kolkata04 Aug 2025AY 2020-21

Bench: the Joint Commissioner (Appeals) or the Commissioner of Income Tax (Appeals) under Section 246A of the Income Tax Act, 1961, on 13/02/2024, though belatedly, vide e-Filing Acknowledgement Number: 110773970130224 for the Assessment Year 2021-22 belatedly on the grounds explained WARI the Statement of Facts and Grounds of Appeal.

Section 245Section 246ASection 250Section 253

ground of belated filing of Appeal, is unlawful and in violation of principles of natural justice. 2. The disallowance of expenditure pursuant to Section 36(1)(va) of the Income Tax Act, 1961, amounting to 29,84,656/- based only on the Audit Report under Section 44AB ... specified under the Employees' Provident Funds and Miscellaneous Provisions Act, 1952, vis-à-vis Employees share of contribution as dealt with by Section 36(1)(va) of the Act, as detailed below: Though, admittedly the Assessee has delayed in depositing the contributions under the funds as specified under Section 36

Karnataka Housing Board, Bangalore vs. DCIT, Exemptions Cirlce-1, Bangalore

In the result, the appeals filed by the assessee is allowed with the above directions

ITA 171/BANG/2025[2017-18]Status: DisposedITAT Bangalore04 Aug 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Padamchand Khincha, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 11Section 13(8)Section 143(3)Section 2(15)

concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from tax under section 11 of the Income

Karnataka Housing Board, Bangalore vs. DCIT, Exemptions Cirlce-1, Bangalore

In the result, the appeals filed by the assessee is allowed with the above directions

ITA 170/BANG/2025[2013-14]Status: DisposedITAT Bangalore04 Aug 2025AY 2013-14

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Padamchand Khincha, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 11Section 13(8)Section 143(3)Section 2(15)

concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from tax under section 11 of the Income

Karnataka Housing Board, Bangalore vs. DCIT, Exemptions Cirlce-1, Bengaluru

ITA 169/BANG/2025[2012-13]Status: DisposedITAT Bangalore04 Aug 2025AY 2012-13

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Appellant: Shri Padamchand Khincha, AdvocateFor Respondent: Smt. Nandini Das, CIT(DR)(ITAT), Bengaluru
Section 11Section 13(8)Section 143(3)Section 2(15)

debts' of Rs.18,10,68,604/-; and ii) in concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from

Karnataka Housing Board, Bangalore vs. DCIT, Bangalore

ITA 1283/BANG/2016[2011-12]Status: DisposedITAT Bangalore04 Aug 2025AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

For Respondent: Date of hearing
Section 11Section 13(8)Section 143(3)Section 2(15)

debts' of Rs.18,10,68,604/-; and ii) in concluding that these expenses were not in the nature of irrecoverable debts covered within section 36(1)(vii). 7.2 Without prejudice to the above, even if the said amount is added back to the total income, the same is exempt from

Dy. Commissioner of Income Tax, Central Circle-3(3), Mumbai vs. Prateek Apparels Private Limited, Karnataka

In the result, appeals of the Revenue in ITA No

ITA 3099/MUM/2025[2018-19]Status: DisposedITAT Mumbai04 Aug 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Shankarlal Jain & Shri Satish KumarFor Respondent: Shri R A Dhyani, (CIT DR)
Section 132Section 132(4)Section 143(3)Section 153ASection 36(1)(iii)

Ground no.1 of the appeal pertains to the disallowance of Rs.64,29,336/- out of interest paid under provision of section 36(1)(iii). Facts of the case are already discussed in para 3.2 above. In response to the query made by the AO, it was submitted that the advances ... material on record to establish any nexus between the borrowed funds and interest free advances. Accordingly, the addition made towards interest disallowance under Section 36(1)(iii) amounting to Rs.64,29,336/- was deleted. 13. During hearing before us, the ld.AR reiterated the same contentions as made before the authorities

Dy. Commissioner of Income Tax, Central Circle -3(3), Mumbai vs. Prateek Apparels Private Limited, Karnataka

In the result, appeals of the Revenue in ITA No

ITA 2936/MUM/2025[2014-15]Status: DisposedITAT Mumbai04 Aug 2025AY 2014-15

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Shankarlal Jain & Shri Satish KumarFor Respondent: Shri R A Dhyani, (CIT DR)
Section 132Section 132(4)Section 143(3)Section 153ASection 36(1)(iii)

Ground no.1 of the appeal pertains to the disallowance of Rs.64,29,336/- out of interest paid under provision of section 36(1)(iii). Facts of the case are already discussed in para 3.2 above. In response to the query made by the AO, it was submitted that the advances ... material on record to establish any nexus between the borrowed funds and interest free advances. Accordingly, the addition made towards interest disallowance under Section 36(1)(iii) amounting to Rs.64,29,336/- was deleted. 13. During hearing before us, the ld.AR reiterated the same contentions as made before the authorities

Assistant Commissioner of Income Tax, Circle-25(1), Delhi vs. Unison Hotels Private Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 4471/DEL/2024[2014-15]Status: DisposedITAT Delhi04 Aug 2025AY 2014-15

Bench: Ms.Madhumita Roy & Shri Manish Agarwal[Assessment Year : 2014-15] Acit, Vs Unison Hotels Pvt.Ltd., Cirlce-25(1), Plot No.2, Nelson Mandela Road, Delhi Vasant Kunj, Phase-2Nd, New Delhi-110070. Pan-Aaacu0455C Appellant Respondent Revenue By Shri Virender Kumar Singh, Sr.Dr Assessee By Ms. Kavita Jha, Sr.Adv., Shri Himanshu Agarwal, Adv. & Shri Akash Shukla, Adv. Date Of Hearing 06.05.2025 Date Of Pronouncement 04.08.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 12.08.2024 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Cit(A), Delhi-8/10712/2016-17 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Order Dated 23.12.2016 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is A Private Limited Company & Is Running Hotels. The Return Of Income Was E-Filed On 29.11.2014, Declaring Total Income At Inr 7,21,35,196/-. The Case Was Selected For Scrutiny Under Cass By Way Of Issue Of Notice U/S 143(2) Of The Act On 01.09.2015. Thereafter, Various Notices Were Issued From Time To Time & Submissions Were Taken From The Assessee & Finally, The Assessment Was Completed At An Income Of Inr 30,38,83,394/- By Making Various Additions/Disallowances.

Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(vii)

assessee reversed the said provision and claimed deduction thereof. * Thus, the mandatory conditions for claiming write-off of bad-debts in terms of section 36(1)(vii) of the Act have been fulfilled. [(i) the provision for doubtful debt was debited and the corresponding debtor account has been credited, thereby ... instant case, we find that the assessee successfully demonstrate that both the conditions have been fulfilled for claiming bad debts as per section 36(1)(vii) of the Act. Ld. CIT(A) after considering these facts, has deleted the disallowance by observing as under:- D. Findings i) “The Assessing Officer

Assistant Commissioner of Income Tax, Central Circle-2, Kanpur. vs. M/S. Sushrut Institute of Plastic Surgery Private Limited, Lucknow

The appeal of the Department stands dismissed whereas the Cross Objection of the assessee stands allowed

ITA 30/LKW/2023[2019-20]Status: DisposedITAT Lucknow31 Jul 2025AY 2019-20

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2019-20 The Acit V. M/S Sushrut Institute Of Plastic Central Circle 2 Surgery Private Limited Kanpur 29, Shahmeena Road Lucknow Tan/Pan:Aaics2582G (Appellant) (Respondent) C.O. No.15/Lkw/2023 [Arising Out Of Ita No.30/Lkw/2023] Assessment Year: 2019-20 M/S Sushrut Institute Of Plastic V. The Acit Surgery Private Limited Central Circle 2 29, Shahmeena Road Kanpur Lucknow Tan/Pan:Aaics2582G (Cross - Objector) (Respondent)

For Appellant: Shri Ashish Jaiswal AdvocateFor Respondent: Shri Sunil Kumar Rajwanshi, D.R
Section 115BSection 133ASection 142ASection 143(3)Section 2(24)(x)Section 271ASection 36(1)(va)Section 69Section 69A

date. The AO, treated the same as income of the assessee under section 2(24)(x) of the Act, on which deduction under section 36(1)(va) of the Act was disallowed and added to the total income of the assessee. The AO completed the assessment under section

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 1228/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD "ी संजय गग", "ाियक सद

Gruh Finance Ltd., Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 138/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2014-15

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD "ी संजय गग", "ाियक सद

Gruh Finance Ltd., Ahmedabad vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

Appeal is dismissed

ITA 855/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD "ी संजय गग", "ाियक सद

The ACIT, Circle-2(1)(1), Ahmedabad vs. Gruh Finance Ltd., Ahmedabad

Appeal is dismissed

ITA 1126/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD "ी संजय गग", "ाियक सद

Confidence Petroleum India Limited, Mumbai vs. Deputy Commissioner of Income Tax- Circle 1(2)(1), Mumbai

In the result, the appeal of the assessee is dismissed

ITA 3699/MUM/2025[2020-21]Status: DisposedITAT Mumbai31 Jul 2025AY 2020-21

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3699/Mum/2025 (नििाारण वर्ा / Assessment Year: 2020-21) Confidence Petroleum V/S. Deputy Commissioner Of India Limited बिाम Income Tax -Circle B-13, Prabhu Krupa 1(2)(1), Mumbai Society, Nanda Patkar Pratishtha Bhavan, 3 Rd & 4Th Road, Santacruz West, Floors, 101, M.K. Road, Mumbai 400054 Mumbai 400020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacd3658C Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri S.V. Joshi राजस्व की ओर से /Revenue By: Shri Virabhadra S. Mahajan, Sr. Dr. स िवाई की िारीख / Date Of Hearing 16.07.2025 घोर्णा की िारीख/Date Of Pronouncement 31.07.2025

For Appellant: Shri S.V. JoshiFor Respondent: Shri Virabhadra S. Mahajan, Sr
Section 139(1)Section 143(1)Section 143(3)Section 250Section 36(1)(va)

That the learned CIT(A) erred in law and facts of the case and confirmed the addition of Rs. 4,99,749/- under section 36(1)(va) as processed by CPC and carried P a g e | 2 ITA No. 3699/Mum/2025 Ay 2020-21 Confidence Petroleum India Limited ... filing of return and hence the same should be allowed as a deduction. Ld. CIT(A) observed that as per provisions of Section 36(1)(va) of the Act, the assessee is entitled to claim the deduction in respect of the employee’s contributions only if there are credited

Tara Engineers& Contractors Private Limited, Mumbai vs. ITO Ward 14(3)(2), Mumbai

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

ITA 1194/MUM/2025[2018-19]Status: DisposedITAT Mumbai31 Jul 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary () Assessment Year: 2018-19 Tara Engineers & Contractors Pvt. Ito-14(3)(2), Ltd., Aayakar Bhavan, M.K. Road, Vs. Room No. 3, Sumitra Bhavan, Opp Mumbai-400020. Bpcl Main Gate Chembur, Mumbai-400074. Pan No. Aaect 3095 R Appellant Respondent

For Respondent: Mr. Venugopal Nair
Section 143(1)Section 143(1)(a)

period provided u/s 43B of the Act or beyond the period provided Tara Engineers & Contractors Pvt. Ltd Tara Engineers & Contractors Pvt. Ltd under section 36(1)(va) of the Act. under section 36(1)(va) of the Act. In absence of this primary of this primary finding of fact

Niket Ramesh Shah, Mumbai vs. ACIT, Central Circle -1 Thane, Mumbai

ITA 4958/MUM/2024[2019-20]Status: DisposedITAT Mumbai31 Jul 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry (Jm) & Shri Omkareshwar Chidara (Am) Mr. Niket Ramesh Shah Acit Central Circle 401, Radheshayam Chsl 1, Thane Vishnu Nagar, Naupada Vs. Thane West-400 602. Pan : Appellant Respondent

For Appellant: Shri Leyaqat Ali AafaquiFor Respondent: Shri Subodh Ratnaparakhi
Section 36(1)(iii)Section 37(1)

partnership firm, for the alleged reason that interest free investments were made out of interest bearing borrowed funds, without appreciating the provisions of section 36(1)(iii) of the IT Act, 1961 and ignoring fact that the concerned investments were for the business purposes only and accordingly the interest expenditure ... allowable as revenue expenditure as per section 36(1)(iii) of the IT Act, 1961 and should be so allowed in computing total income. 2. The Hon CIT(A) erred in upholding the alternative argument of the Id AO to support the addition of Rs. 16,80,298/-, by relying

ACIT-2(3)(1), Mumbai vs. Tata Capital Limited (Successor to Tata Cleantech Capital Limited), Mumbai

In the result, appeal of the Revenue is dismissed

ITA 3456/MUM/2024[2016-17]Status: DisposedITAT Mumbai31 Jul 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Anish Thacker, CAFor Respondent: Shri Hemanshu Joshi, Sr. DR
Section 143(3)Section 147Section 148Section 36(1)(viii)Section 80Section 80I

under: “Upon perusal of computation of income, it is seen that the assessee has claimed a deduction of 7,50,00,000/- under section 36(1)(viii). As per Explanation (g) of section 36(1)(vii) of the Income Tax Act, 1961, "infrastructure facility" means - (ii) an undertaking referred ... also requested to furnish the details of computation of profit derived from the eligible business in A.Y 2016-17- As per section 36(1)(viii), any other financial corporation (refer Explanation 1 (a)) shall be allowed a deduction, of an amount not exceeding 20% of the profits derived from eligible

Tinna Rubber and Infrastructure Ltd, Delhi vs. DCIT, Circle-25(1), Delhi

ITA 817/DEL/2025[2018-19]Status: DisposedITAT Delhi31 Jul 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

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

sole substantive ground canvassed in its instant former appeal ITA No. 816/Del/2025 seeks to reverse both the learned lower authorities’ action invoking section 36(1)(va) ESI/PF disallowance of Rs.18,14,176/- in the CPC’s section 143(1) processing dated 21.08.2023 and upheld in the lower appellate discussion ... share of contribution towards Employees State Insurance and Provident Fund of Rs.28,21,065/- 2 | P a g e ITA Nos.816 & 817/Del/2025 under Section 36 (1) (va) of the Act of 1961 were disallowed, inasmuch as, on the said date, the issue with regard to delayed deposit of contribution with

Tinna Rubber and Infrastructure Ltd, Delhi vs. DCIT, Circle-25(1), Delhi

ITA 816/DEL/2025[2022-23]Status: DisposedITAT Delhi31 Jul 2025AY 2022-23

Bench: Shri Satbeer Singh Godara & Shri Avdhesh Kumar Mishra

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

sole substantive ground canvassed in its instant former appeal ITA No. 816/Del/2025 seeks to reverse both the learned lower authorities’ action invoking section 36(1)(va) ESI/PF disallowance of Rs.18,14,176/- in the CPC’s section 143(1) processing dated 21.08.2023 and upheld in the lower appellate discussion ... share of contribution towards Employees State Insurance and Provident Fund of Rs.28,21,065/- 2 | P a g e ITA Nos.816 & 817/Del/2025 under Section 36 (1) (va) of the Act of 1961 were disallowed, inasmuch as, on the said date, the issue with regard to delayed deposit of contribution with