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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)

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Vivek Gupta, Kolkata

Appeal of the revenue is dismissed and cross objection is partly allowed

ITA 1592/KOL/2025[2017-18]Status: DisposedITAT Kolkata20 Jan 2026AY 2017-18

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 133ASection 143(1)Section 250Section 68

Ground No. 4. 8. The issue raised in Ground No. 5 against the deletion of disallow- ance of Rs. 61,151/- made under section 36(1)(iii) of the Act on account of interest paid on alleged bogus loans. Since we have upheld the order

Capgemini Technology Services India Limited (Successor to Liquidhub India Private Limited), Pune vs. Assistant Commissioner of Income Tax, Circle 1(1), Pune

In the result, the Appeal filed by the Assessee is allowed

ITA 2753/PUN/2025[2020-21]Status: DisposedITAT Pune19 Jan 2026AY 2020-21

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2753/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Capgemini Technology V Assessment Unit, Services India S Income Tax Limited(Successor To Liquid Department. Hub India Private Limited), Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase Iii, Midc Sez, Village Man, Taluka Mulshi, District Pune – 411057. Pan: Aaacl8943J Appellant/ Assessee Respondent /Revenue Assessee By Shri Sudin Sabnis & Shri Siddhesh Khandalkar Revenue By Shri Madhukar Anand-Jcit(Through Virtual) Date Of Hearing 05/01/2026 Date Of Pronouncement 19/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The 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.2020-21 Dated 02.09.2025 Emanating From The Penalty Order Passed Under Section

Section 115JSection 143(3)Section 155Section 155(18)Section 18Section 250Section 270ASection 270A(6)(a)Section 40

concerned 3. Less: Tax impact on account of other 32,27,62,439 retrospective amendments [e.g section 40(a)(ii) and section 36(1)(va) of Capgemini (other than sr. no. 2) 5 4. Balance MAT Credit brought forward 5,67,32,85,499 ITA No.2753/PUN/2025 [A] 2.2 Ld.AR ... concerned 3. Less: Tax impact on account of other 32,27,62,439 retrospective amendments [e.g section 40(a)(ii) and section 36(1)(va) of Capgemini (other than sr. no. 2) 4. Balance MAT Credit brought 5,67,32,85,499 forward 5.3 These facts have not been disputed

Modi Home Products Limited, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 5315/MUM/2025[2014-15]Status: DisposedITAT Mumbai19 Jan 2026AY 2014-15

Bench: Shri Om Prakash Kant () & Ms Kavitha Rajagopal () Assessment Year: 2014-15 Modi Home Products Limited Income Tax Officer, Second Floor, Akash Ganga, Ward 5(2)(3), Vs. 89, Bhulabhai Desai Road, Mumbai- 400020 Mumbai- 400026 Pan No. Aaacm 4151 D Appellant Respondent

For Appellant: Mr. Anil Kumar Jain (Virtually
Section 143(3)

been taken into account in computing taxable income in any year, as mandated by secti income in any year, as mandated by section 36(1)(vii) read with on 36(1)(vii) read with section 36(2) of the Act. section 36(2) of the Act. 4.3 Before ... custom authorities and paper book page No. 29 show amount with custom authorities as written written off . 4.5 Under the provisions provisions of section 36(1)(vii) for claiming of bad of section 36(1)(vii) for claiming of bad debt written off as deduction as deduction, firstly, the amount

Imperial Life Science Private Limited, Delhi vs. Assistant Commissioner, Delhi

ITA 5320/DEL/2025[2020-21]Status: DisposedITAT Delhi19 Jan 2026AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 139(1)Section 143(1)Section 154Section 36(1)(va)

during the course of hearing with the able assistance coming from the Revenue side that both the learned lower authorities herein have invoked section 36(1)(va) ESI/PF disallowance amounting to Rs.20,43,335/- for AY 2019-20 and Rs.19

Imperial Life Science Private Limited, Delhi vs. Assistant Commissioner, Delhi

ITA 5319/DEL/2025[2019-20]Status: DisposedITAT Delhi19 Jan 2026AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Amitabh Shukla

Section 139(1)Section 143(1)Section 154Section 36(1)(va)

during the course of hearing with the able assistance coming from the Revenue side that both the learned lower authorities herein have invoked section 36(1)(va) ESI/PF disallowance amounting to Rs.20,43,335/- for AY 2019-20 and Rs.19

Sis Limited, Patna vs. ACIT, Delhi

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

ITA 341/PAT/2024[2018-19]Status: DisposedITAT Patna16 Jan 2026AY 2018-19

Bench: SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER SHRI SONJOY SARMA (Judicial Member)

Section 143(1)(a)Section 143(2)Section 250Section 36(1)(va)Section 43B

sustaining the addition of Rs.5,60,01,339/- without recording any justifiable dissatisfaction with the appellant's explanations for claim of deduction under section 36(1)(va) of the Income Tax Act, 1961 ('the Act'). 3. That on the facts and circumstances of the case, the CIT(A) has erred ... claiming deduction is deposit within the due date, the incorrect reporting ESI/PF Portal per-se cannot be a ground of disallowance under section 36(1)(va) of the Act. 7. That on the facts and circumstances of the case, the CIT(A) has erred, both on facts

ACIT, Circle-10(1), New Delhi vs. Index Securities & Research Pvt Ltd, New Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 2181/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68

written off without appreciating that the loan which is not granted during regular course of business. 6.1 Failure to Satisfy Conditions Under Section 36(1)(vi): The deduction of bad debts is governed by section 36(1)(vii), which mandates that for such claim to be allowable: e The debt ... business; ¢ Does not satisfy the character of a trading loss; e Is clearly capital in nature, and hence, not eligible for deduction under section 36(1)(vii). 6.4 Inapplicability of Section 36(1)(vila)(d): The Assessee has not claimed the benefit under section 36(1)(viia

Smt. Raj Bala, Chandigarh vs. DCIT/ACIT Circle 1(1), Chandigarh

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

ITA 1142/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh14 Jan 2026AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Smt. Geetinder Mann, CIT DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(va)Section 43B

employees’ share of PF/ESI contributions had been deposited after the statutory due dates prescribed under the respective Acts. Applying the provisions of section 36(1)(va) read with section 2(24)(x), the CPC held that belated deposits of employees’ contributions could not be allowed as deduction. It was further ... contributions were deposited after the prescribed due dates. The CIT(A) placed reliance on the amendments introduced by the Finance Act, 2021 to sections 36(1)(va) and 43B, clarifying that the benefit of section 43B is not available in respect of employees’ contributions. The CIT(A) further held that

DCIT, New Delhi vs. Omax Autos Ltd, Gurgaon

ITA 3055/DEL/2025[2020-21]Status: DisposedITAT Delhi14 Jan 2026AY 2020-21

Bench: Shri Anubhav Sharma & Shri Amitabh Shukla

For Appellant: Sh. Rohit Jain, AdvFor Respondent: Sh. Mukesh Kumar Jha, CIT, DR
Section 143(3)Section 43(6)Section 45

Even otherwise, it is a settled law that for claiming deduction for bad debts in accordance with provisions of section 36(1)(vii) of the Act, it is not necessary for the assessee to establish that the debt, in fact, has become irrecoverable; it is enough if the bad debt

The India Cements Ltd., Chennai vs. DCIT, Corporate Circle-1(1), Chennai

The appeal of the assessee is allowed

ITA 2663/CHNY/2025[2021-22]Status: DisposedITAT Chennai13 Jan 2026AY 2021-22

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2663/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

For Respondent: Mr. Shiva Srinivas, CIT
Section 139(1)Section 143Section 250Section 43BSection 80Section 80I

other fund for the The India Cements Ltd. :- 15 -: welfare of such employees" as per section 2(24)(x) of the Act. Section 36(1)(va) provides that any sum received by the assessee from any of his employees to which the provisions of section 2(24)(x) apply

Haribhakti & Co LLP, Mumbai vs. The Deputy Commissioner of Income Tax Central Circle 2(3), Mumbai

In the result, appeal filed by the assesse bearing ITA No

ITA 1610/MUM/2025[2021-22]Status: DisposedITAT Mumbai13 Jan 2026AY 2021-22

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Alpesh DharodFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(1)Section 250Section 36(1)(va)

1)of the Act, date of order 28/12/2022. 2. The brief facts of the case are that the assessee claimed deduction under section 36(1)(va) of the Act in respect of employees' contribution to Provident Fund (PF). The assessee deposited the said employees' contribution with a delay. During ... processing of the return, the Ld. AO rejected the assessee's claim for deduction under section 36(1)(va) of the Act and made an addition amounting to Rs.15,72,131/-. Aggrieved by the said adjustment, the assessee preferred an appeal before the Ld. CIT(A). The assessee contended that

Ktm Impex Private Limited, Panipat vs. ITO, Panipat

In the result, appeal filed by the assessee is allowed

ITA 2377/DEL/2025[2019-20]Status: DisposedITAT Delhi09 Jan 2026AY 2019-20

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Amit Kaushik, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

bank statements, and interest computation. The said interest expenditure was incurred wholly and exclusively for the purpose of business and is allowable under section 36(1)(iii). The disallowance is unjustified in the absence of any finding that borrowed funds were used for non-business purposes or that the transaction ... interest computation. Accordingly, ITA No.2377/Del/2025 the said interest expenditure was incurred wholly and exclusively for the purpose of business and is allowable under section 36(1)(iii). He further submitted that the assessee’s books were never rejected nor any specific defect pointed out. The addition was made arbitrarily despite

Saurashtra Cement Limited, Porbandar vs. The Principal Commissioner of Income Tax, Jamnagar

In the result, appeal filed by the assessee is allowed

ITA 307/RJT/2024[2018-19]Status: DisposedITAT Rajkot08 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.307/Rjt/2024 िनधा"रणवष"/ Assessment Year: 2018-19 Saurashtra Cement Ltd. Principal Commissioner Of Near Railway Station, बनाम Income Tax, Jamnagar, Saurashtra Cement Factory, Jamnagar Vs. P.O. Ranavav, Adityana Road, Porbandar, Gujarat-360560 Pan : Aahfs5211J (अपीलाथ"/Assessee) : (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Vimal Desai, Ld.Ar राज" की ओर से/Revenue By : Shri Sanja Punglia, Ld. Cit-Dr सुनवाई की तारीख/Date Of Hearing : 16/10/2025 घोषणा की तारीख/Date Of Pronouncement : 08/01/2026 Order

For Appellant: Shri Vimal Desai, ld.ARFor Respondent: Shri Sanja Punglia, Ld. CIT-DR
Section 143(3)Section 14ASection 263Section 36(1)(iii)

आयकर अपीलीय अिधकरण, राजकोट "ायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI

Surya International Pvt. Ltd., Lucknow vs. Central Processing Centre, Bangalore

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

ITA 323/LKW/2025[2020-21]Status: DisposedITAT Lucknow08 Jan 2026AY 2020-21

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 143(1)Section 2(8)Section 40A(3)

income which does not form part of the total income Particulars Amount Remarks if any i) Amount inadmissible under the proviso to section 36(1)(iii) Nil When the tax auditor reports a figure in Sl.No. 21(g) and the tax audit report is filed by the assessee himself

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

claim of bad debt amounting to ₹.852,53,45,072/- debited to the P & L account has been allowed as deduction under section 36(1)(vii) of the Act. In the computation of income for the F.Y. 2020-21 relevant to the AY 2021-22, an amount ... claimed as deduction under section 36(1)(viia)(d) of the Act relating to provision created during the year for bad debts. Since for F.Y. 2021-22, the amount of ₹.99,78,811/- was available as opening balance, bad debts claimed should have been restricted

Windston Springs Pvt Ltd, Mumbai vs. Dy. CIT -8(3)(2), Mumbai

In the result, the appeal for assessment year 2015-16 is allowed

ITA 704/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Respondent byFor Respondent: Shri Arun Kanti Datta, CIT D.R
Section 36(1)(iii)Section 50

that the block of assets had ceased to exist as on 07.01.2014. The Ld. CIT(A) also confirmed the disallowance of interest under section 36(1)(iii) and the disallowance of depreciation by treating the building as capital work-in-progress. 5. Before us, the Ld. Authorised Representative submitted that

Windston Springs Pvt Ltd, Mumbai vs. Dy. CIT -8(3)(2), Mumbai

In the result, the appeal for assessment year 2015-16 is allowed

ITA 703/MUM/2025[2015-16]Status: DisposedITAT Mumbai08 Jan 2026AY 2015-16

Bench: Shri Saktijit Dey & Shri Jagadish

For Appellant: Respondent byFor Respondent: Shri Arun Kanti Datta, CIT D.R
Section 36(1)(iii)Section 50

that the block of assets had ceased to exist as on 07.01.2014. The Ld. CIT(A) also confirmed the disallowance of interest under section 36(1)(iii) and the disallowance of depreciation by treating the building as capital work-in-progress. 5. Before us, the Ld. Authorised Representative submitted that

M/S Ashapura Developers, Mumbai vs. ACIT Circle 1, Thane, Mumbai

In the result, the appeal of the assessee is allowed

ITA 5795/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar

Section 143(3)Section 250Section 271(1)(c)Section 36(1)(iii)Section 68

Applying interest at the rate of 12 percent on the alleged interest-free advances, the Assessing Officer disallowed Rs. 25,01,730/- under section 36(1)(iii) of the Act. Accordingly, the total income of the assessee was assessed as under: i. Returned income: Rs. 21,67,520/- ii Addition ... under section 68 : Rs. 34,89,041/- ii. Disallowance of interest on unsecured loans : Rs. 3,13,109/- iv. Disallowance under section 36(1)(iii) : Rs. 25,01,730/- 3. Thus, the assessed total income was determined at Rs. 84,71,400/-. Penalty proceedings under section 271(1)(c) were

Asstt. Commisioner, Mumbai vs. Supreme Lake View Bungalows Private Limited, Powai, Mumbai

In the result the appeal of the revenue bearing ITA No

ITA 5735/MUM/2025[2022]Status: DisposedITAT Mumbai07 Jan 2026

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Rakesh JoshiFor Respondent: Shri Arun Kanti Datta (CIT DR)
Section 139Section 143(1)Section 143(3)Section 250Section 36(1)(iii)Section 68

View Bungalows Private Limited of Rs.55,49,75,562/- with the total income of the assessee. Further the addition was also confirmed under section 36(1)(iii) of the Act amount of Rs.15,37,228/-. Aggrieved assessee filed an appeal before the Ld.CIT(A). The Ld. CIT(A) considering ... submissions of the assessee deleted the addition made under section 68 amount of Rs.55,4,975,562/-. But related to addition under section 36(1)(iii) amount of Rs.15,37,228/- was confirmed. Bering aggrieved revenue filed an appeal before us. But the assessee has not challenged the impugned appellate

Income Tax Officer, Ward 5, Sangli. vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta

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

ITA 2375/PUN/2025[2018-19]Status: DisposedITAT Pune06 Jan 2026AY 2018-19

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2375/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Ito, Ward-5, Sangli. Vs. Shree Ganesh Nagari Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent C. O. No.49/Pun/2025 (Arising Out Of Ita No.2375/Pun/2025) िनधा"रण वष" / Assessment Year : 2018-19 Shree Ganesh Nagari Vs. Ito, Ward-5, Sangli. Sahakari Pat Sanstha Maryadit, Ashta, Tal. Walwa, Dist. Sangli, Sangli- 416301. Pan : Aaaas8248R Appellant Respondent Revenue By : Shri Umesh Phade Assessee By : Shri Sarang Gudhate Date Of Hearing : 25.11.2025 Date Of Pronouncement : 06.01.2026 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Revenue Is Directed Against The Order Dated 05.08.2025 Passed By Ld. Cit(A)/Nfac For The Assessment

For Appellant: Shri Sarang GudhateFor Respondent: Shri Umesh Phade
Section 143(3)Section 28Section 36(1)(va)Section 80P(2)Section 80P(2)(d)

before the due date whereas the appellant has not paid the employees contribution on or before the due date. As per section 36(1)(va) of the Act, if the employees contribution is not paid to the government account on or before the due date, the same is not allowable ... erred in not allowing deduction u/s 80P of Rs. 58,631/- being employees' contribution towards Provident Fund by invoking the provisions of Section 36(1)(va) of the Income-tax Act, 1961, on the alleged ground that the said contribution was not deposited on or before 5 C.O. No.49/PUN/2025