“Section 36(1)(va)”

Section References (mined)Section 36Section 36(1)(va)2,467 judgments

The decision most relied on for Section 36(1)(va) is CIT v. AIMIL Ltd. (321 ITR 508), cited in 1,629 judgments on BharatTax.

Leading authorities on Section 36(1)(va)

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. Ghatge Patil Transports Ltd.

368 ITR 749 · 2014 · High Court

609

citing judgments

Deduction for employees' contributions to PF and ESIC is allowable under Section 43B if paid before the due date for filing the return under Section 139(1); similarly, delayed deposits of employers' contributions to ESIC and PF are also allowable.

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 36(1)(va)

Raiganj Central Co-Operative Bank Ltd., Uttar Dinajpur vs. A.C.I.T., Circle - 2(2), Jalpaiguri

In the result, the appeal for A

ITA 1887/KOL/2024[2017-2018]Status: DisposedITAT Kolkata23 May 2025AY 2017-2018

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115Section 143(3)Section 156Section 250Section 40

justified by confirming the disallowance of Employees' Contribution to Provident Fund of Rs.16,84,704/- as income u/s 2(24)(x) read with section 36(1)(va) of the Income Tax Act, 1961 and adding the same with returned income. 10. THAT the Ld. CIT (A)-NFAC, has grossly erred ... justified by confirming the disallowance of Employees' Contribution to Provident Fund of Rs.6,23,893/ as income u/s 2(24)(x) read with section 36(1)(va) of the Income Tax Act, 1961 and adding the same with returned income without considering the fact that due date under the relevant

Raiganj Central Co-Operative Bank Ltd., Uttar Dinajpur vs. D.C.I.T., Circle - 2(2), Jalpaiguri

In the result, the appeal for A

ITA 1886/KOL/2024[2015-2016]Status: DisposedITAT Kolkata23 May 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 115Section 143(3)Section 156Section 250Section 40

Sameer Chile, Damoh vs. Income Tax Officer, CPC

In the result, the appeal of the assessee is dismissed

ITA 29/JAB/2024[2021-22]Status: DisposedITAT Jabalpur21 May 2025AY 2021-22

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Dr. Hemant S. Modh, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR

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

IN THE INCOME TAX APPELLATE TRIBUNAL JABALPUR BENCH, JABALPUR (By virtual mode) BEFORE SH. KUL BHARAT, VICE PRESIDENT AND SH

Gyan Cirkitronics Pvt. Ltd, Lucknow vs. ACIT-3, Lucknow-New

In the result, the appeal of the assessee is dismissed

ITA 403/LKW/2024[2020-21]Status: DisposedITAT Lucknow21 May 2025AY 2020-21

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2020-21 Gyan Cirkitronics Private Vs. Acit-3, Lucknow-New Limited, Plot No. 6-B, Malviya Nagar Aishbagh, Lucknow, U.P. 226004 Pan:Aabcg2210J (Appellant) (Respondent) Assessee By: Sh. Ashwini Kumar, C.A. Revenue By: Sh. Sunil Kumar Rajwashi, Addl Cit Dr Date Of Hearing: 23.04.2025 Date Of Pronouncement: 21.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Jcit(A), Thane, Dated 03.05.2024 Passed Under Section 250 Of The Income Tax Act, 1961 Partly Allowing The Appeal Of The Assessee Which Was Filed Against The Order Of The Ld. Ao Under Section 154 Dated 29.04.2022. The Grounds Of Appeal Are As Under:- “1. That The Income Returned Should Have Been Accepted. 2. That Application Filed Under Section 154 Should Have Been Accepted. 3. The Addition Made By Cpc Was Not Within The Preview Of Adjustments Which Could Be Made Under Section 143(1)(A). 4. That The Learned Lower Court Erred In Facts & Legal Aspects Of The Case In Not Allowing Expenses Of Rs. 833161/- Invoking Section 36(1)(Va), 5. That The Order Passed Is Against The Merit, Circumstances & Legal Aspects Of The Case. 5. That The Appellant Seeks Permission To Modify And/Or Add Any Other Ground Or Grounds Of Appeal As The Circumstances Of The Case Might Require Or Justify.”

For Appellant: Sh. Ashwini Kumar, C.AFor Respondent: Sh. Sunil Kumar Rajwashi, Addl CIT DR

Section 143(1)(a)Section 154Section 250Section 36(1)(va)

That the Learned Lower Court erred in facts and legal aspects of the case in not allowing expenses of Rs. 833161/- invoking section 36(1)(va), 5. That the order passed is against the merit, circumstances and legal aspects of the case. 5. That the appellant seeks permission to modify

ACIT 6(3), Mumbai vs. Grasim Industires Ltd, Mumbai

In the result Revenue's appeal is dismissed

ITA 6758/MUM/2011[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Shri Saktijit Dey, Vp & Shri N.K. Billaiya, Am

Section 36(1)(va)

course of assessment proceeding, the AO noticing that employees' contribution to PF was not paid within the due date prescribed in terms with Section 36(1)(va) of the Income Tax Act, 1961 (in short the 'Act') disallowed the deduction claimed. Learned First Appellate Authority confirmed the disallowance. 5. Before

Grasim Industries Ltd 9Corporate Finance Division), Mumbai vs. Asst CIT Cir 6(3), Mumbai

ITA 5982/MUM/2011[2008-09]Status: DisposedITAT Mumbai21 May 2025AY 2008-09

Bench: Shri Saktijit Dey, Vp & Shri N.K. Billaiya, Am

For Appellant: Shri J.D. Mistri, Sr. AdvocateFor Respondent: Date of Hearing

Section 36(1)(va)

Sanjeev Kumar Bakshi, Haryana vs. Assessing Officer, Ward 3, Haryana

In the result, appeal of the Assessee is dismissed

ITA 297/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh20 May 2025AY 2018-19

Bench: The Due Date Of Filing The Return Of Income Under Section 139(1) Of The Income-Tax Act, 1961. 2 5. The Facts In Brief Are That The Return Of Income Was Processed Under Section 143(1) Of The Act By The Cpc, Bangalore, Disallowing Employees’ Contribution To Pf/Esi To The Extent Of Rs. 29,87,930/-, Relying Upon The Dates Of Actual Payment Furnished In The Tax Audit Report, Which Indicated That The Payments Were Made Beyond The Statutory Due Dates.

For Appellant: Ms. Priyanka Jindal, AdvocateFor Respondent: Dr Ranjit Kaur, Addl. CIT, Sr. DR

Section 139(1)Section 143(1)Section 36(1)(va)Section 43B

Gujarat State Road Transport Corporation [(2014) 41 taxmann.com 100] and the amendment introduced by the Finance Act, 2021, which inserted Explanation 2 to section 36(1)(va), clarifying that the provisions of section 43B do not apply to employees’ contributions. 7. We have heard the rival contentions and perused ... return of income. 7.1 The Hon’ble Supreme Court has categorically held that section 43B applies only to employer’s contributions and that section 36(1)(va) governs the employees’ share, and the same must be deposited within the time prescribed under the relevant welfare Acts. 7.2. Respectfully following

Adroit Corporate Services Private Limited, Mumbai vs. Commissioner of Income Tax, Churchgate

In the result, the appeal as well the stay application of the assessee stand dismissed

ITA 6288/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 May 2025AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Ms. Neera SawantFor Respondent: Mr. Ram Krishn Kedia, Sr. DR

Section 143(1)Section 36(1)Section 36(1)(iii)Section 36(1)(va)Section 43B

paid after the due date stipulated under the respective Acts , accordingly he disallowed the claim of the assessee in term of section 36(1)(va) of the Act. Secondly, regarding loan of Rs. 60,00,000/- to Shri. Mukesh, the assessee failed to substantiate Adroit Corporate Services Private

Eagle Hunter Solutions Limited, New Delhi vs. CIT Appeals-25, New Delhi

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

ITA 480/DEL/2025[2020-21]Status: DisposedITAT Delhi19 May 2025AY 2020-21

Bench: Shri M. Balaganesh & Sh. Yogesh Kumar U.S.Eagle Hunter Solutions Vs Commissioner Of Income Limited Tax (Appeals)-25 61C, Kalu Sarai, Sarvapriya New Delhi Vihar, New Delhi-110016 Pan: Aabce0565E Appellant Respondent

Section 143(1)Section 143(3)Section 2(24)(x)Section 270A(2)Section 270A(2)(a)Section 36(1)

Year 2020-21. 2.Grounds taken in this appeal are as under: “1. Disallowance as per the provisions of section 2(24)(x) r.w. section 36(1) (va)- The Assessment Unit Income Tax Department has erred in law as well as on facts in adding ... provisions of section 2(24)(x) r.w. section 36(1) (va) on account of delayed payment of employee contribution towards PF/ESI. 2 Eagle Hunter Solutions Ltd. Vs. CIT(A) 2. Penalty Proceedings initiated u/s 270A(2)(a)- The Assessment Unit Income Tax Department has erred in law as well

Bajajsons Ltd., Ludhiana vs. DCIT, Central Circle III, Ludhiana

In the result, the appeal stand dismissed

ITA 935/CHANDI/2024[2021-2022]Status: DisposedITAT Chandigarh16 May 2025AY 2021-2022

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 935/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) M/S Bajajsons Ltd. Dcit बनाम/ C-103 Phase V Focal Point Central Circle Iii Vs. Ludhiana 141010 Ludhiana-141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacb-6875-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sarabjit Garg (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 23-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021- 22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 27-06-2024 In The Matter Of An Intimation Issue By Cpc U/S 143(1) Of The Act On 04-03-2021 Disallowing Late Payment Of Employees’ Contribution To Pf / Esi For Rs.5.44 Lacs In Terms Of Sec.43B R.W.S. 36(1)(Va) As Well As Sec.2(24)(X). The Ld. Cit(A) Confirmed The Same, Inter-Alia, By Relying Upon The Decision Of Hon’Ble Apex Court In The Case Of Checkmate

For Appellant: Sh. Sarabjit Garg (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR

Section 143(1)Section 14BSection 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

character as an income (albeit deemed), by virtue of Section 2(24)(x) and therefore, subjected to conditions spelt out by Explanation to Section 36(1)(va) i.e., depositing such amount received or deducted from the employee on or before the due date. In other words, there is a marked

Kuldeep Singh, Ludhiana vs. ITO Ward (3) (1), Ludhiana

In the result, the appeal stand dismissed

ITA 717/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh16 May 2025AY 2018-19

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 717/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Kuldeep Singh Ito Ward No (3)(1) बनाम/ 33F Jmd Mall Opp. Railway Station Aayakar Bhawan Vs. Punjab 141001 Rishi Nagar, Punjab. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bchps-1635-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : None ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 24-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 22-04-2024 In The Matter Of An Rectification Intimation Issued By Cpc U/S 154 Of The Act On 21-06-2023. At The Time Of Hearing, None Appeared For Assessee. Left With No Option, The Appeal Was Heard With The Able Assistance Of Ld. Sr. Dr Who Stated That The Issue Stood Squarely Covered Against The Assessee By The Decision Of Hon’Ble Apex Court.

For Appellant: NoneFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR

Section 143(1)Section 154Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

Satish Kumar Rana, Kangra vs. Income Tax Officer, Kangra Himachal Pradesh

In the result, the appeal stand dismissed

ITA 1190/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh16 May 2025AY 2020-21

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 1190/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) Shri Satish Kumar Rana Ito-Ward 42(3)(3) बनाम/ H.No. 90, Dhaniara, Duhak Mumbai Vs. Thural, Kangra, Hp – 176075 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaupr-3944-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Written Submissions ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 15-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2020-21 Arises Out Of An Order Of Learned Addl. / Joint Commissioner Of Income Tax (Appeals), Hyderabad [Cit(A)] Dated 18-12-2023 In The Matter Of An Intimation Issued By Cpc U/S 143(1) Of The Act On 16-12-2019. At The Time Of Hearing, None Appeared For Assessee. However, The Written Submissions As Filed By The Assessee Were Duly Considered. The Ld. Sr. Dr Stated That The Issue Stood Squarely Covered Against The Assessee By The Decision Of Hon’Ble Apex Court. The Registry Has Noted Delay Of 281 Days In The Appeal Which Stand Condoned.

For Appellant: Written SubmissionsFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR

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

Kerala State Financial Enterprises Limited, Thrissur vs. DCIT Circle 1(1) & Tps, Thrissur

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

ITA 307/COCH/2023[2018-19]Status: DisposedITAT Cochin14 May 2025AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Harikrishnanunny, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR

Section 143Section 263Section 36(1)(va)Section 37(1)Section 40Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

M/S Inditrade Capital Ltd (Previously Known As "Jrg Securities Ltd"), Kochi vs. The ITO, Corporate Ward1(1), Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 243/COCH/2023[2017-18]Status: DisposedITAT Cochin14 May 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Aneesh Vishwanathan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 32(1)(ii)

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

M/S Inditrade Capital Ltd (Previously Known As, Kochi vs. The ITO, Corporate Ward1(1), Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 242/COCH/2023[2014-15]Status: DisposedITAT Cochin14 May 2025AY 2014-15

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Aneesh Vishwanathan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 32(1)(ii)

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

M/S Inditrade Capital Ltd (Previously Known As, Kochi vs. The ITO, Corporate Ward1(1), Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 241/COCH/2023[2013-14]Status: DisposedITAT Cochin14 May 2025AY 2013-14

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Aneesh Vishwanathan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 32(1)(ii)

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

M/S Inditrade Capital Ltd (Previously Known As, Kochi vs. The ITO, Corporate Ward1(1), Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 240/COCH/2023[2012-13]Status: DisposedITAT Cochin14 May 2025AY 2012-13

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Aneesh Vishwanathan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 32(1)(ii)

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

M/S Inditrade Capital Ltd (Previously Known As, Kochi vs. The ITO, Corporate Ward1(1), Kochi

In the result, the appeal filed by the assessee stands allowed

ITA 239/COCH/2023[2011-12]Status: DisposedITAT Cochin14 May 2025AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Sandeep Singh Karhail

For Appellant: Sri.Aneesh Vishwanathan, CAFor Respondent: Smt.Leena Lal, Senior AR

Section 143(3)Section 32(1)(ii)

IN THE INCOME TAX APPELLATE TRIBUNAL COCHIN BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member & Shri Sandeep Singh Karhail

Springer Nature Technology and Publishing Solutions Private Limited, Pune vs. The Deputy Commissioner of Income-Tax, Circle 5, Pune

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

ITA 2800/PUN/2024[2020-21]Status: DisposedITAT Pune14 May 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Vishal KalraFor Respondent: Shri Ajay Kumar Keshari

Section 10ASection 115JSection 143(1)Section 143(3)Section 144BSection 234ASection 250Section 36(1)Section 36(1)(va)

appreciating the submissions made by the Appellant in its proper perspective. Disallowance of delayed contribution of employees contribution to ESIC under section 36(1) (va) of the Act 6. The learned AO has erred in confirming the disallowance on account of delayed contribution of employees contribution to ESIC under section ... filed for the year under consideration and hence, do not warrant disallowance. Disallowance of delayed contribution of employees contribution to ESIC under section 36(1)(va) of the Act 5. The learned ADIT-CPC has erred in making disallowance on account of delayed contribution of employees contribution to ESIC under

Springer Nature Technology and Publishing Solutions Private Limited, Pune vs. The Assessment Unit, Income Tax Department and the Deputy Commissioner of Income-Tax, Circle 5, Pune

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

ITA 1141/PUN/2023[2020-21]Status: DisposedITAT Pune14 May 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Vishal KalraFor Respondent: Shri Ajay Kumar Keshari

Section 10ASection 115JSection 143(1)Section 143(3)Section 144BSection 234ASection 250Section 36(1)Section 36(1)(va)