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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)

Acme Cleantech Solutions Private Limited, Gurgaon vs. DCIT, Circle-1(1), New Delhi

In the result, both the appeals of the assessee are partly allowed as indicated above

ITA 508/DEL/2022[2017-18]Status: DisposedITAT Delhi31 Jul 2025AY 2017-18

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 36(1)(iii)

made any addition qua the long term capital loss. 3. The Assessing Officer, however, sustained the following disallowances a) Disallowance made under section 36(1)(iii), b) Disallowance of 14A, c) Addition of notional interest on outstanding receivables from AE. 4. Aggrieved with the order of the AO has come

Acme Cleantech, Haryana vs. ACIT, Circle-1 (1), New Delhi

In the result, both the appeals of the assessee are partly allowed as indicated above

ITA 2142/DEL/2022[2018-19]Status: DisposedITAT Delhi31 Jul 2025AY 2018-19

Bench: SHRI PRAKASH CHAND YADAV (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 36(1)(iii)

made any addition qua the long term capital loss. 3. The Assessing Officer, however, sustained the following disallowances a) Disallowance made under section 36(1)(iii), b) Disallowance of 14A, c) Addition of notional interest on outstanding receivables from AE. 4. Aggrieved with the order of the AO has come

Janta Land Promoters Private Limited, Mohali vs. Income Tax Officer Ward 6(1) Chandigarh, Mohali

In the result, appeal of the assessee is partly allowed

ITA 907/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh30 Jul 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 907/Chd/2024 "नधा"रण वष" / Assessment Year : 2017-18 बनाम M/S Janta Land Promoters Pvt.Ltd. The Ito, Sco 39-42, Sector 82, Ward 6(1), Vs Mohali. Chandigarh. "थायी लेखा सं./Pan /Tan No: Aabcj3450D अपीलाथ"/Appellant ""यथ"/Respondent "नधा"रती क" ओर से/Assessee By : Shri Pankaj Bhalla, Ca राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr.Dr तार"ख/Date Of Hearing : 07.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 30.07.2025

For Appellant: Shri Pankaj Bhalla, CAFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr.DR
Section 143(3)Section 250(6)Section 253(5)Section 28Section 36(1)(va)

grounds, however, its grievance revolves around two issues, namely, ld. CIT (Appeals) has erred in confirming the addition made with the aid of Section 36(1)(va) of the Act with regard to the, (a) Employees’ contribution not paid before the due date provided under PF & ESI acts

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1050/MUM/2025[2015-16]Status: DisposedITAT Mumbai30 Jul 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(1)

therefore, the interest in respect to those loans and advances was held to be for non-business purpose and accordingly disallowed under section 36(1)(iii) of the Act. There is no finding recorded by the Assessing Officer to cover the said disallowance under the definition of the undisclosed income

Swaran Nadhan Salaria, Mumbai vs. DCIT, Central Circle 1(2), Mumbai

In the result all appeals of the assesses from AY 2014-15 to AY

ITA 1049/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jul 2025AY 2014-15

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Rakesh JoshiFor Respondent: Mr. Virabhadra S. Mahajan, Sr. DR
Section 132Section 139(1)Section 142Section 143(3)Section 153ASection 271(1)(c)Section 37(1)

therefore, the interest in respect to those loans and advances was held to be for non-business purpose and accordingly disallowed under section 36(1)(iii) of the Act. There is no finding recorded by the Assessing Officer to cover the said disallowance under the definition of the undisclosed income

ACIT Circle 3 3 1, Mumbai vs. Sicom Investments & Finance Limited, Mumbai

In the result the appeals filed by the revenue stands dismissed

ITA 5669/MUM/2024[2015]Status: DisposedITAT Mumbai30 Jul 2025

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10Section 10(38)Section 115Section 115JSection 143(2)Section 14A

Facts of the case narrated in the assessment order and written submission made by the Appellant has been considered. Conjoined reading of Section 36(1) (vii) along with Sec. 36(2) (i) of the I.T.Act, indicates that the amount of any bad debt written off, in the books of accounts

Shiv Pratap Singh Kunwar, Uttar Pradesh vs. Jurisdictional Assessing Officer, Circle 1(1)(1) Meerut, Range-14, Uttar Pradesh

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

ITA 85/DEL/2025[2019-2020]Status: DisposedITAT Delhi30 Jul 2025AY 2019-2020

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2019-20] Shiv Pratap Singh Kunwar, Vs Jurisdictional Assessing 508, Begum Bagh, Meerut, Officer, Circle-1(1)(1), Uttar Pradesh-250001 Range-14, Meerut, Pan-Afmpk3273Q Uttar Pradesh-250001 Appellant Respondent Appellant By Shri Hemant Jain, Adv. Respondent By Shri Ajay Kumar Arora, Sr.Dr Date Of Hearing 15.07.2025 Date Of Pronouncement 30.07.2025 Order Per Manish Agarwal, Am : The Captioned Appeal Is Filed By The Assessee Against The Order Dated 29.11.2023 Passed By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld.Cit(A)”] In Appeal No. Nfac/2018-19/10029654 U/S 250 Of The Income Tax Act, 1961 [“The Act”] Pertaining To Assessment Year 2019-20. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Engaged In The Business Of Security Agency. The Appellant Filed His Return Of Income On 17.08.2020, Declaring Total Income Of Inr 46,84,309/- & The Same Was Assessed U/S 143(1) On 11-12-2020 At The Income Of Rs.87,33,921/- Wherein The Cpc Made The Disallowance On Account Of Delayed Payment Of Employees Contribution Towards Pf/Esi U/S 36(1)(Va) Of The Act. 3. Against This Order, The Assessee Preferred Appeal Before Ld.Cit(A) Who Dismissed The Appeal Of The Assessee Vide Impugned Order Dated 29.11.2023 Thus, The Assessee Is In Appeal Before Us.

Section 143(1)Section 250Section 36(1)(va)

solitary issue in the present appeal is with respect to disallowance of employees contribution towards PF & ESI being paid delayed in terms of section 36(1)(va) of the Act. 8. Before us, the only contention of the assessee was that it had paid the employees contribution in accordance with

Ciena India Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 4(2), Delhi

Accordingly, Ground No. 2 raised by the assessee is allowed

ITA 3715/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Jul 2025AY 2020-21

Bench: Shri Ramit Kochar & Ms. Madhumita Royciena India Private Vs. Dcit, Circle 4(2) Limited, Co Kochhar & C.R. Building, Co. Law Office, Suite No. Delhi – 110002 1120-1121, 11Th Floor, Tower A, Dlf Towers Jasola, New Friends Colony S.O Zakir Nagar So, South East, Delhi – 110025, "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaccc6131B Appellant .. Respondent

For Appellant: Sh. Yishu Goel, AdvFor Respondent: Sh. S.K. Jadhav, CIT. DR
Section 143(3)Section 144BSection 144C(1)Section 234ASection 234CSection 36(1)(va)Section 43B

circumstances of the case and in law, the Ld. AO has erred in making the addition amounting to INR 94,400 under Section 36(1)(va) of the Act in respect of employee contribution to labour welfare fund as the same was deposited within the statutory timelines provided under ... this ground of appeal become infructuous and hence, dismissed as infructuous. 7. Ground No. 6 relates to addition amounting to Rs.94,400/- under Section 36(1)(va) on account of employees contribution of the Labour Welfare Fund. It is the case of the assessee that the same was deposited within

Trident Limited, Ludhiana vs. Deputy Commissioner of Income Tax, CC-1, Ludhiana

The appeal is treated as allowed for statistical purposes

ITA 1113/CHANDI/2024[2022-23]Status: DisposedITAT Chandigarh29 Jul 2025AY 2022-23

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 250Section 36(1)(va)

allowable only if paid within the time prescribed under the respective statutes. The delay, however minimal, disentitles the assessee from claiming deduction under section 36(1)(va) of the Act. We have also gone through the documents and the decision of 8. Coordinate Bench. The first document filed ... interpreted strictly. Any delay beyond the due date prescribed under the respective statutes would render such contribution ineligible for deduction under section 36(1)(va) of the Act. It is equally true that the Hon’ble Apex Court has not carved out any 10. exception to the strict compliance mandated

Janata Sahakari Bank Limited, Satara vs. Assistant Commissioner of Income Tax, Circle, Satara

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

ITA 2/PUN/2025[2017-2018]Status: DisposedITAT Pune29 Jul 2025AY 2017-2018

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Janata Sahakari Bank Limited, V The Acit, Satara. S Satara. 179, Bhawani Peth, Rajpath, Satara – 415001. Maharashtra. Pan: Aaajj0029N Appellant/ Assessee Respondent / Revenue Assessee By Shri Pramod S Shingte – Ar Revenue By Smt Sonal L Sonkavde –Addl.Cit(Dr) Date Of Hearing 05/06/2025 Date Of Pronouncement 29/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 01.11.2024, Emanating From Order U/S.143(3) Of The Income Tax Act, 1961, Dated 28.12.2019. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(3)Section 250Section 270A(2)Section 36(1)Section 36(1)(viia)

Loss Account does not constitute additional income. Ld.CIT(A) noted that however the Assessing Officer treated the said amount as a claim under section 36(1)(viia) of the Income Tax Act. Ld.CIT(A) ITA No.2/PUN/2025 [A] has merely brushed the contention of the Assessee that the amount of Rs.42 ... less than the figure of Rs.1,27,98,078/- which is undisputed figure of deduction worked out as per provision of Section 36(1)(viia) at the rate of ten percent of average rural branches advances as per working shown in the Tax Audit Report. Thus Rs.96

Patidar Builder Pvt Ltd, Bhopal vs. AO, Bhopal

Appeal is allowed partly

ITA 557/IND/2023[2011-12]Status: DisposedITAT Indore28 Jul 2025AY 2011-12

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2011-12 Patidar Builder Pvt. Ltd. Assessing Officer E-4/382 Arera Colony, (Jcit-Range-2, Bhopal) बनाम/ Bhopal Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aaacp8931A Assessee By Shri Pankaj Shah & Soumya Bumb, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 23.07.2025 Date Of Pronouncement 28.07.2025

Section 143(2)Section 143(3)Section 2(22)(e)Section 36(1)(iii)Section 40A(3)Section 41(1)

facts and circumstances of the case and in law the learned CIT(A) erred in confirming the addition made by Assessing Officer under Section 36(1)(iii) of the Act in respect of interest expenses of Rs. 129648 claimed by the Appellant. The Appellant prays that the said disallowance

M/S.Mahogany Logistics Services Pvt. Ltd., Madurai vs. PCIT, Madurai-1

In the result, the appeal filed by the assessee is dismissed

ITA 1631/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 Jul 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1631/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mahogany Logistics Services Vs. The Principal Commissioner Of Private Limited, Income Tax-1, 10, Jawahar Road, Chokkikulam, Madurai. Madurai 625 002. [Pan:Aafcd8781R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 30.04.2025 घोषणा की तारीख /Date Of Pronouncement : 28.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax 1, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company [Earlier Known As M/S. Drsr Logistics Services Private Limited] Filed Its Return Of Income For The Ay 2018-19 Claiming Loss Of ₹.31,28,98,436/- Under 2

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri S. Senthil Kumaran, CIT
Section 139(9)Section 143(3)Section 201Section 263Section 36Section 37Section 40

scrutiny proceedings, the Assessing Officer disallowed 30% of interest expenditure to an extent of ₹.9,26,75,342/-. He submits that section 36(1)(iii) of the Act provides deduction for the amount of interest paid in respect of capital borrowed for the purpose of business or profession and placed ... profit, growth, etc. and such expenditure is “wholly and exclusively” for the purpose of business. 8. He submits that the main requirement of section 36(1) of the Act is that the interest amount which is sought to be deducted in computing business income under section

Prime Comfort Products (P) Ltd., New Delhi vs. DCIT, CPC, Bengaluru

In the result, this assessee’s appeal is partly allowed for statistical purposes

ITA 1262/DEL/2021[2018-19]Status: DisposedITAT Delhi28 Jul 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

For Appellant: Shri J.P. Sharma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 139(1)Section 143(1)Section 36(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’, NEW DELHI Before Shri Satbeer Singh Godara, Judicial Member And Shri

Dileshwar Nath, New Delhi vs. Jurisdictional Assessing Officer, Ward 68(5), Delhi, Range Code- 73, New Delhi

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

ITA 75/DEL/2025[2020-2021]Status: DisposedITAT Delhi25 Jul 2025AY 2020-2021

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(1)Section 250Section 36(1)(va)

solitary issue in both the appeals is with respect to disallowance of employees contribution towards PF & ESI being paid delayed in terms of section 36(1)(va) of the Act. 8. Before us, the only contention of the assessee was that it had paid the employees contribution in accordance with

Dileshwar Nath, Delhi vs. Jurisdictional Assessing Officer, Ward 68(5), Delhi, Range Code- 73

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

ITA 74/DEL/2025[2019-2020]Status: DisposedITAT Delhi25 Jul 2025AY 2019-2020

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal

Section 143(1)Section 250Section 36(1)(va)

solitary issue in both the appeals is with respect to disallowance of employees contribution towards PF & ESI being paid delayed in terms of section 36(1)(va) of the Act. 8. Before us, the only contention of the assessee was that it had paid the employees contribution in accordance with

Assistant Commissioner of Income Tax, Circle 2(1)(1), Vadodara, Race Course vs. Unimed Technologies Limited, Halol

ITA 632/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

used for repayment of trade liabilities and for regular business requirements, and hence, the entire interest expenditure was allowable as revenue expenditure under section 36(1)(iii) of the Act. Additionally, the CIT(A) directed the Assessing Officer to rectify the computation of tax by granting due credit ... Tribunal and observed that in view of the adequacy of own funds and the absence of any direct nexus, the disallowance under section 36(1)(iii) was not justified. Accordingly, the disallowance of Rs.1,76,03,597/- was deleted in full and the ground raised by the assessee was allowed

Unimed Technologies Limited, Panchmahal vs. The ACIT, Circle-2(1)(1), Vadodara

ITA 623/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Jul 2025AY 2016-17

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2016-17 Unimed Technologies Limited Acit, Cir.2(1)(1) Survey No.22 & 22, Vs. Vadodara. Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B Asstt.Year : 2016-17 Acit, Cir.2(1)(1) Unimed Technologies Limited Vadodara. Vs. Survey No.22 & 22, Baska, Ujeti Halol Panchmahal Pan : Aaace 4022 B (Applicant) (Responent) : Shri Bandish Soparkar, Ar Assessee By : Shri Sher Singh, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 17/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 24/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Sher Singh, CIT-DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 271(1)(b)Section 271(1)(c)Section 36(1)(iii)Section 37(1)

used for repayment of trade liabilities and for regular business requirements, and hence, the entire interest expenditure was allowable as revenue expenditure under section 36(1)(iii) of the Act. Additionally, the CIT(A) directed the Assessing Officer to rectify the computation of tax by granting due credit ... Tribunal and observed that in view of the adequacy of own funds and the absence of any direct nexus, the disallowance under section 36(1)(iii) was not justified. Accordingly, the disallowance of Rs. 1,76,03,597/- was deleted in full and the ground raised by the assessee

Salt Lake Service Station, Kolkata vs. DCIT, 49(1), Kolkata

Appeal is partly allowed

ITA 431/KOL/2025[2017-18]Status: DisposedITAT Kolkata24 Jul 2025AY 2017-18

Bench: SHRI GEORGE MATHAN, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 115BSection 250Section 271ASection 36Section 36(1)(v)Section 36(1)(va)Section 37(1)Section 40Section 69A

four additions on account of cash deposited during demonetisation period under Section 69A of the Act (Rs. 6,06,52,500/-), disallowance under Section 36(1)(v) of the Act (Rs. 22,654/-), disallowance under Section 40(a)(ia) of the Act (Rs. 54,000/-) and disallowance under Section ... extended due date notified by the EPF Authorities and hence could not have been considered within the sweep of Explanation 1 to section 36(1)(va) of the Income Tax Act, 1961. 4. That on the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals

M/S. Gopal Dhara Tea Co. Pvt. Ltd., Kolkata vs. ITO, Ward 4(4), Kolkata

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 347/KOL/2025[2019-20]Status: DisposedITAT Kolkata24 Jul 2025AY 2019-20

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(1)Section 250Section 36(1)Section 43B

आयकर अपीलीय अधिकरण कोलकाता 'एसएमसी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘SMC’ BENCH, KOLKATA श्री संजय

Glitch Media Private Limited, Mumbai vs. Deputy Commissioner of Income Tax - 1(3)(1), Mumbai

In the result the appeal filed by the assessee stands partly

ITA 2178/MUM/2025[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 139(1)Section 143(1)Section 143(3)Section 234ASection 234BSection 234CSection 250Section 270ASection 36(1)(va)Section 37(1)

ensure that only legitimate taxes are collected and, therefore, should delete the additional disallowance of Rs.1,69,68,083. Without prejudice, disallowance of section 36(1)(va) of the Act of Rs.9,24,959 on account of alleged late deposit of contribution made to Provident Fund 8. Without prejudice ... above, erred in confirming the disallowance of Rs.9,24,959 under section 36(1)(va) of the Act towards contribution to Provident Fund made beyond the due date as per the respective Act, but deposited before the due date of filing the return as per the Act as per section