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“Section 2(24)(i)”

Section References (mined)Section 2Section 2(24)(i)15 judgments

The decision most relied on for Section 2(24)(i) is CIT v. AIMIL Ltd. (321 ITR 508), cited in 1,629 judgments on BharatTax.

Leading authorities on Section 2(24)(i)

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).

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. 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.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

(i) CIT v. Merchem Ltd.
378 ITR 443 · 2015 · High Court
631
citing judgments

Belated remittance of employees' contribution to ESI and PF, even if deposited before the due date for filing the return of income under Section 139(1), is not allowed as a deduction. This disallowance falls under Section 36(1)(va) read with Section 2(24)(x), as Section 43B applies only to employer's contributions.

CIT v. Ponni Sugars & Chemicals Ltd.
306 ITR 392 · 2008 · Supreme Court
577
citing judgments

The "Purpose Test" determines whether an incentive or subsidy is a capital or revenue receipt for income tax purposes. If the incentive's purpose is to enable an assessee to set up a new industry or make investments in capital assets, it is a capital receipt and not taxable.

CIT v. Gujarat State Road Transport Corpn
41 Taxmann.com 100 · 2014 · High Court
540
citing judgments

Employees' contributions to provident fund or other welfare funds are deductible under section 36(1)(va) only if paid by the due date specified in the respective welfare fund enactments, and section 43B does not extend this period to the income tax return filing due date under section 139(1).

Judgments citing Section 2(24)(i)

Vijaya Bank Employees Co-Operative Credit Society, Bangalore vs. The Income Tax Officer, Ward 7(2)(3), Bangalore

In the result the appeal filed by the assessee is allowed

ITA 1524/BANG/2025[2022-23]Status: DisposedITAT Bangalore15 Dec 2025AY 2022-23

Bench: Shri Prashant Maharishiassessment Years 2022-23 Appellant / Assessee Vijaya Bank Employees Cooperative Credit Society, R No 1, 67, Ii Floor, K H Road Shantinagar Bangalore 560027 Karnataka Respondent The Income Tax Officer, Ward 7 (2) (3) Bmtc Building Koramangala Bangalore 560095 Pan Aaaav4696A For Appellant Shri Prasanna N Uralal Advocate For Respondent Shri Ganesh R Ghale, Advocate Date Of Hearing 04-11-2025 Date Of Pronouncement 15-12-2025 O R D E R

Section 139(1)Section 143(2)Section 80PSection 80P(2)(a)Section 80P(2)(d)

attributable to any of the specified activities in section 80P (2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(i) to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically 'business profits' into the definition

ITO-19(3)(1), Mumbai vs. The Jackson Coop Credit Society of the Employees of Western Railway Limited, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 2976/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kant & Shri Raj Kumar Chauhan

Section 142(1)Section 250Section 56Section 62Section 80PSection 80P(2)(a)

Western Railway Limited specified activities mentioned in section 80P(2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(1) of the Act to include profits and gains of business. This subsection is an inclusive provision. The Parliament has included specifically ‘business profits' into

Jambo Credit and Thrift Co-Operative Society Limited, Jaipur vs. ITO-6(1), Jaipur

ITA 1109/JPR/2025[2018-19]Status: DisposedITAT Jaipur12 Nov 2025AY 2018-19

Bench: This Appellate Tribunal Feeling Aggrieved By Order Dated 12.06.2024, Passed By Learned Cit(A), Nfac, Delhi, Relating To The Assessment Year 2018-19, As Thereby The Appeal Filed By The Appellant Has Been Dismissed.

For Appellant: Ms. Apksha Kalra, AdvFor Respondent: Shri Gaurav Awasthi, JCIT

specified activities mentioned in section 80P(2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(i) of the Act to include profits and gains of business. This sub-section is an inclusive provision. The Parliament has included specifically business profits' into the definition

Income Tax Officer, Wanaparthy Block vs. Tamilnadu Special Police Employees Cooperative, Tsp Camp

In the result the appeal of the revenue is dismissed

ITA 363/CHNY/2025[2020-21]Status: DisposedITAT Chennai15 Jul 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:363/Chny/2025 िनधा"रण वष" / Assessment Year: 2020-21 Income Tax Officer, Tamilnadu Special Police Non-Corporate Ward -7(3), Vs. Employees Cooperative, Chennai – 600 034. Avadi, Chennai – 600 054. [Pan:Aafat-0366-E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Sita Krishnamoorthy, J.C.I.T. ""थ" की ओर से/Respondent By : Shri. G. Reddi Prakash, C.A. सुनवाई की तारीख/Date Of Hearing : 12.06.2025 घोषणा की तारीख/Date Of Pronouncement : 15.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: This Appeal By The Revenue Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2020-21, Dated 11.10.2024. 2. At The Outset, We Find That There Is A Delay Of 34 Days In Appeal Filed By The Revenue, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Revenue & Also Hearing Both The Parties, We Find That There Is A Reasonable Cause For The Revenue In Not Filing Appeal On Or Before The Due Date Prescribed Under The Law & Thus

For Appellant: Ms. Sita Krishnamoorthy, J.C.I.TFor Respondent: Shri. G. Reddi Prakash, C.A
Section 80PSection 80P(1)Section 80P(2)Section 80P(2)(a)Section 80P(2)(d)

specified activities in Section 80P(2) of the Act, would be eligible for deduction. The word "income" has been defined under Section 2(24)(i) of the Act to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically "business profits into the definition

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward-4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 805/COCH/2024[2018-19]Status: DisposedITAT Cochin29 Apr 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R
Section 250Section 80PSection 8O

eligible for deduction'. 9.2 While dealing with the definition of the word 'income', it is held: 'the word 'income' has been defined under section 2(24)(i) of the Act to include profits and gains. This sub-section is an inclusive provision. Parliament has included specifically business profits into

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 803/COCH/2024[2017-18]Status: DisposedITAT Cochin29 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R
Section 250Section 80PSection 8O

eligible for deduction'. 9.2 While dealing with the definition of the word 'income', it is held: 'the word 'income' has been defined under section 2(24)(i) of the Act to include profits and gains. This sub-section is an inclusive provision. Parliament has included specifically business profits into

The Kundara Panchayath Service Cooperative Bank Ltd, Kollam vs. Income Tax Officer, Ward 4, Kollam

In the result, appeals filed by the assessee are allowed

ITA 802/COCH/2024[2012-13]Status: DisposedITAT Cochin29 Apr 2025AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Keshav Dubey

For Appellant: Shri G.Surendranath Rao, A.RFor Respondent: Smt. Leena Lal, Sr. D.R
Section 250Section 80PSection 8O

eligible for deduction'. 9.2 While dealing with the definition of the word 'income', it is held: 'the word 'income' has been defined under section 2(24)(i) of the Act to include profits and gains. This sub-section is an inclusive provision. Parliament has included specifically business profits into

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 162/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh12 Feb 2025AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV, AM आयकर अपील सं . / ITA No.160, 161 & 162/ Chd/2023 निर्धारण वर्ष / Assessment Year : 2017-18, 2012-13 & 2013-14 The Jyoti Co-operative Non Agricultural Thrift & Credit Society Ltd. Sirmour, Solan, HP-173025 स्थायी लेखा सं. / PAN NO: AAABT1453G अपीलार्थी/Appellant बनाम The ITO H.P Ward-Nahan, Sirmour प्रत्यर्थी/Respondent निर्धारिती की ओर से/Assessee by : Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, Advocate राजस्व की ओर से / Revenue by : Dr. Ranjeet K

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

surplus funds in fixed deposits. 6.2 It was further held by the AO that the term or expression, 'income' has been defined in section 2(24). By way of Finance Act, 2006, sub-section (viia) was inserted to stipulate that profits and gains of business of banking, including credit facilities ... Income'. The aforesaid definition of term 'income' is inclusive and a broad one. Thus, the income of the assessee would be taxable under section 2(24), including the income earned by way of interest on the FDRs with banks. Section 80P provides partial exemption, restricted to the specified 'earning

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 161/CHANDI/2023[2012-13]Status: DisposedITAT Chandigarh12 Feb 2025AY 2012-13

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

surplus funds in fixed deposits. 6.2 It was further held by the AO that the term or expression, 'income' has been defined in section 2(24). By way of Finance Act, 2006, sub-section (viia) was inserted to stipulate that profits and gains of business of banking, including credit facilities ... Income'. The aforesaid definition of term 'income' is inclusive and a broad one. Thus, the income of the assessee would be taxable under section 2(24), including the income earned by way of interest on the FDRs with banks. Section 80P provides partial exemption, restricted to the specified 'earning

The Jyoti Co-Operative Non Agricultural Thrift & Credit Society Ltd., Sirmour vs. ITO, Ward, Nahan

In the result, the assessee is not eligible for deduction on interest on deposits placed with scheduled commercial banks under section 80(P)(2)(a)(i) of the Act and the appeal of the assessee is di...

ITA 160/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh12 Feb 2025AY 2017-18
For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Parveen Sharma, AdvocateFor Respondent: Dr. Ranjeet Kaur, Sr. DR
Section 142(1)Section 80Section 80P(2)Section 80P(2)(a)

surplus funds in fixed deposits. 6.2 It was further held by the AO that the term or expression, 'income' has been defined in section 2(24). By way of Finance Act, 2006, sub-section (viia) was inserted to stipulate that profits and gains of business of banking, including credit facilities ... Income'. The aforesaid definition of term 'income' is inclusive and a broad one. Thus, the income of the assessee would be taxable under section 2(24), including the income earned by way of interest on the FDRs with banks. Section 80P provides partial exemption, restricted to the specified 'earning

Taluk Gopalpur Samabay Krishi Unnayan Samity Limited., Medinipur vs. ITO, Ward No-27(3), Haldia

In the result, the appellant fails with respect to ground no

ITA 1152/KOL/2023[2018-19]Status: DisposedITAT Kolkata07 Aug 2024AY 2018-19

Bench: Pradip Kumar Choubey & Sri Sanjay Awasthi

Section 80PSection 80P(2)(d)

attributable to any of the specified activities in section 80P(2) would be eligible for deduction. The word 'income' has been defined under section 2(24)(i) to include profits and gains. This sub-section is an inclusive provision. The Parliament has included specifically 'business profits' into the definition

Roop Kumar Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 386/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

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

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

termed as “real” in view of the surrounding circumstances of this case is factually incorrect, legally misconceived and untenable. (xii) That reference section 2(24)(vi) of the Act supports the claim of the assessee. (xiii) That section 2(24)(i) of the Act is not applicable on the facts ... matter. Issue No.4 is decided in favour of the assessee. ISSUE No.5 – Whether compensation received by assessee is taxable as income under section 2(24)(i)(vi) and (iv) of the Income Tax Act, 1961 OR under section 2(28A) of the Income Tax Act, 1961 ? 16. The Learned PCIT

Shri Basant Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 385/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

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

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

termed as “real” in view of the surrounding circumstances of this case is factually incorrect, legally misconceived and untenable. (xii) That reference section 2(24)(vi) of the Act supports the claim of the assessee. (xiii) That section 2(24)(i) of the Act is not applicable on the facts ... matter. Issue No.4 is decided in favour of the assessee. ISSUE No.5 – Whether compensation received by assessee is taxable as income under section 2(24)(i)(vi) and (iv) of the Income Tax Act, 1961 OR under section 2(28A) of the Income Tax Act, 1961 ? 16. The Learned PCIT

Pankaj Bansal, Gurgaon vs. Pr, CIT (Central), Gurgaon

In the result, ITA.No.383/Del

ITA 384/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

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

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

termed as “real” in view of the surrounding circumstances of this case is factually incorrect, legally misconceived and untenable. (xii) That reference section 2(24)(vi) of the Act supports the claim of the assessee. (xiii) That section 2(24)(i) of the Act is not applicable on the facts ... matter. Issue No.4 is decided in favour of the assessee. ISSUE No.5 – Whether compensation received by assessee is taxable as income under section 2(24)(i)(vi) and (iv) of the Income Tax Act, 1961 OR under section 2(28A) of the Income Tax Act, 1961 ? 16. The Learned PCIT

Abha Bansal, Gurgaon vs. PCIT, Central, Gurgaon

In the result, ITA.No.383/Del

ITA 383/DEL/2021[2017-18]Status: DisposedITAT Delhi31 May 2021AY 2017-18

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

For Appellant: And Shri Lalit Mohan, C.AFor Respondent: Shri Satpal Gulati, CIT-DR
Section 132Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 153B(1)(b)Section 263

termed as “real” in view of the surrounding circumstances of this case is factually incorrect, legally misconceived and untenable. (xii) That reference section 2(24)(vi) of the Act supports the claim of the assessee. (xiii) That section 2(24)(i) of the Act is not applicable on the facts ... matter. Issue No.4 is decided in favour of the assessee. ISSUE No.5 – Whether compensation received by assessee is taxable as income under section 2(24)(i)(vi) and (iv) of the Income Tax Act, 1961 OR under section 2(28A) of the Income Tax Act, 1961 ? 16. The Learned PCIT