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“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)

Kantar Gdc India Private Limited, Hyderabad vs. ACIT., Circle - 2(1), Hyderabad

The appeal of the assessee is partly allowed for statistical purposes

ITA 274/HYD/2024[2017-18]Status: DisposedITAT Hyderabad19 Mar 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri Ajit Kumar Jain, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 115JSection 143(3)Section 156

आआआआ आआआआआआ आआआआआआ, आआआआआआआआ आआआ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO

Rays Power Experts Private Limited, Jaipur vs. Assistant Commissioner of Income Tax, Circle 2, Jaipur

In the result, the appeal of the assesee is allowed for statistical purposes as indicated hereinabove

ITA 1086/JPR/2024[2017-18]Status: DisposedITAT Jaipur18 Mar 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Anand Pareek, AdvocateFor Respondent: Smt. Runi Pal, CIT- DR a
Section 115BSection 143(3)Section 14ASection 250Section 68

commencement expenses, but only if they are incurred before the commencement of the business or within 10 years from the commencement. Similarly, section 36(1)(va) allows deduction for the employer's contribution to provident fund, but only if it is paid within the due date under the relevant

Mohammed Sabirul Islam, Kolkata vs. Income Tax Officer 43(1)Kol, Kolkata

The appeal of the assessee is dismissed

ITA 1206/KOL/2023[2019-2020]Status: DisposedITAT Kolkata18 Mar 2025AY 2019-2020

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rakesh Mishrai.T.A. No. 1206/Kol/2023 Assessment Year: 2019-2020 Mohammed Sabirul Islam,………………...……Appellant 19B/3, Dumdum Road, Near Tank No. 7, Kolkata-700030, West Bengal [Pan:Aaspi4453M] -Vs.- Income Tax Officer,……………………………....Respondent Ward-43(1), Kolkata, 3, Government Place (West), Kolkata-700001 Appearances By: N O N E, Appeared On Behalf Of The Assessee Shri Amuldeep Kaur, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: February 03, 2025 Date Of Pronouncing The Order: March 18, 2025

Section 139(1)Section 36(1)(va)

account of EPF and Rs.9,74,954/- on account of ESI), which was added by the Assessing Officer with the aid of section 36(1)(va) on the ground that the assessee failed to make the payment of employees’ contribution to EPF & ESI account within the due date provided under

Raunaq Epc International Limited, K.M Mathura Road Faridabaad vs. PCIT(Central), Delhi-1, C.R.Building Delhi

Appeal is partly allowed in above terms

ITA 1559/DEL/2024[2018-19]Status: DisposedITAT Delhi18 Mar 2025AY 2018-19

Bench: Sh. Satbeer Singh Godara & Sh. Amitabh Shukla

For Appellant: Sh. M. K. Madan, CAFor Respondent: Sh. Sunil Yadav, CIT-DR
Section 14ASection 263Section 36(1)(va)

section 14A r.w. rule 8D disallowance in very terms. Ordered accordingly. 6. Next comes the second issue between the parties qua applicability of section 36(1)(va) disallowance of Rs.46,20,366/- forming subject matter of adjudication in the PCIT’s revision directions. Learned counsel very fairly submits that

Rajasthan Ex Service Men Welfare Corp Society Limited, Sukh Niwas, Bani Park, Jaipur vs. Income Tax Officer Ward 1(2), Jaipur

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

ITA 1286/JPR/2024[2022-23]Status: DisposedITAT Jaipur17 Mar 2025AY 2022-23

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Suresh Kumar Gupta, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 143(1)Section 36(1)Section 36(1)(va)

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR Mk0 ,l- lhrky{eh

Spb Projects and Consultancy Ltd., Chennai vs. ITO Corp. Ward 6(1), Chennai

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

ITA 3303/CHNY/2024[2022-23]Status: DisposedITAT Chennai14 Mar 2025AY 2022-23

Bench: Shri George George K & Shri Jagadish

For Appellant: Shri N.R.Suresh, F.C.AFor Respondent: Ms. Anitha, Addl.CIT
Section 143(1)Section 201Section 250Section 36(1)(va)Section 37Section 37(1)Section 43B

आयकर अपील"य अ"धकरण,‘सी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी जॉज" जॉज

Sbw Udyog Limited, Prayagraj vs. DCIT, Cir-1, Allahabad

In the result, the appeal of the assessee is dismissed

ITA 27/ALLD/2024[2021-22]Status: DisposedITAT Allahabad13 Mar 2025AY 2021-22

Bench: Sh.Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.2021-22 Sbw Udyog Limited, Vs. Deputy Commissioner Of Income 44, Thornhill Road, Prayagraj Tax, Circle-1, Prayagraj Pan:Aadcs2883B (Appellant) (Respondent) Assessee By: Sh. N.C. Agrawal, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 18.12.2024 Date Of Pronouncement: 13 .03.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed Against The Orders Of The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 On 31.01.2024, Dismissing The Appeal Of The Assessee Against The Orders Of The Cpc Bengaluru, Under Section, 143(1) Dated 17.10.2022. Subsequently, The Said Appeal Was Migrated To The Nfac & Later On, The Appeal Proceedings Were Transferred To The Additional / Jcit(A), Aurangabad, Who Has Dismissed The Appeal Of The Assessee. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because, Income Tax Department, Ministry Of Finance, Government Of India Has Observed In The Notice Under Section 250 Of The Income Tax Act, 1961, Which Reads As Under:- "The Income Tax Department Recognizes & Is Sensitive To The Hardships Being Faced By Taxpayers In Coping With The Challenges Posed By Covid-19 Pandemic." Consequently, Appeal Is Liable To Be Allowed.

For Appellant: Sh. N.C. Agrawal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143Section 250Section 36(1)(va)Section 43B

worked out at Rs.7,59, 83,430/-. A disallowance was made for a sum of Rs.43,04,355/-, as being hit by section 36(1)(va) of the Income Tax Act, 1961. The details were as under:- Month and Nature of Sum recd. Due date of The actual The actual ... Indore AUGUST, ESI 539.00 15.09.2020 539.00 16.09.2020 2020 Total 43,04,355.00 3. The assessee submitted before the ld. CIT(A), that section 36(1)(va) of the Act was to be read with section 43B of the Act and contribution of Provident Fund and ESI paid till the filing

M/S.Aaryavart Infrastructure Pvt. Ltd., Ahmedabad vs. The DCIT, Circle-1(1)(1) Presently Central Circle-1(3), Ahmedabad

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

ITA 219/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad11 Mar 2025AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.219/Ahd/2022 िनधा"रण वष" /Assessment Year : 2012-13 Aaryavart Infrastructure Pvt. Ltd. Dy.Cit बनाम/ Ff – 17/A, Pariseema Complex Circle-1(1)(1) V/S. C.G. Road Presently Cen. Cir.1(3) Navrangpura Ahmedabad Ahmedabad – 380 009 "थायी लेखा सं./Pan: Aadca 4844 Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Aseem Thakkar, Ar Revenue By : Shri Kavan Limbasiya, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 07/03/2025 घोषणा की तारीख /Date Of Pronouncement: 11/03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-11, Ahmedabad [Hereinafter Referred To As “Cit(A)”], Dated 30.03.2022, For The Assessment Year (Ay) 2012-13, Whereby The Cit(A) Has Confirmed The Additions Made By The Assessing Officer [Hereinafter Referred To As “Ao”] Under Section 68 Of The Income Tax Act, 1961 [Hereinafter Referred To As “The Act”]. Aaryavart Infrastructure Pvt.Ltd. Vs. Dcit Asst. Year : 2012-13

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri Kavan Limbasiya, Sr. DR
Section 143(3)Section 2(24)(x)Section 40Section 68

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “बी“, अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD सु"ी सुिच"ा का"ले

Selvan Nirmala, Salem vs. ACIT, Circle-1, Hosur

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

ITA 3109/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Mar 2025AY 2017-18

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 3109/Chny/2024 ननिाजरण वर्ज / Assessment Year: 2017-18 Selvan Nirmala, Acit Shop No.6, Dddc Building, V. Circle -1, Sub-Jail Road, Maruthi Nagar, Krishnagiri- 636 007. Hosur – 635 109. [Pan: Aeapn-6574-Q] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Bhupendran, Advocate प्रत्यथी की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 24.02.2025 घोर्णा की तारीख/Date Of Pronouncement : 11.03.2025

For Appellant: Mr. S. Bhupendran, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(3)Section 250Section 36(1)(va)Section 44A

आयकर अपीलीय अधिकरण, ‘बी’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI श्री जॉजज जॉजज के, उपाध्यक्ष

Ariba Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(1), Bengaluru

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

ITA 1587/BANG/2024[AY 2020-21]Status: DisposedITAT Bangalore07 Mar 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Mr. Aliasgar Rampurawala, C.AFor Respondent: Ms. Nandini Das, CIT (DR)
Section 143(3)Section 144C(5)Section 92C

record. In the present cases, it is not in dispute that the assessee deposited the contribution of PF & ESI belatedly in terms of section 36(1)(va) of the Act. However, the said deposits were made prior to filing of return of income u/s 139(1

Dy. Commissioner of Income Tax-5(2)(1), Mumbai vs. Aditya Birla Housing Finance Limited, Mumbai

ITA 4611/MUM/2024[2020-21]Status: DisposedITAT Mumbai03 Mar 2025AY 2020-21

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ronak DoshiFor Respondent: Dr. K. R. Subhash
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Dy. Commissioner of Income Tax-5(2)(1), Mumbai vs. Aditya Birla Housing Finance Limited, Mumbai

ITA 4610/MUM/2024[2021-22]Status: DisposedITAT Mumbai03 Mar 2025AY 2021-22

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ronak DoshiFor Respondent: Dr. K. R. Subhash
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Dy. Commissioner of Income Tax-5(2)(1), Mumbai vs. Aditya Birla Housing Finance Limited, Mumbai

ITA 4609/MUM/2024[2022-23]Status: DisposedITAT Mumbai03 Mar 2025AY 2022-23

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Ronak DoshiFor Respondent: Dr. K. R. Subhash
Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Amenity Appliances Pvt. Ltd., Kolkata vs. ITO, Ward 10(2), Kolkata

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

ITA 668/KOL/2024[2018-19]Status: DisposedITAT Kolkata28 Feb 2025AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Ito, Ward 10(2) Amenity Appliances Pvt. Ltd. Aaykar Bhavan P-7, 181, Dumdum Road, Chowringhee Square, Kolkata-700074 Vs. Kolkata-700069, West Bengal West Bengal (Appellant) (Respondent) Pan No. Aaica4412D Assessee By : Shri Vidhi Ladia, Ar Revenue By : Shri Subhro Das, Dr Date Of Hearing: 12.02.2025 Date Of Pronouncement : 28.02.2025

For Appellant: Shri Vidhi Ladia, ARFor Respondent: Shri Subhro Das, DR
Section 143(1)Section 2(24)Section 36(1)(va)

issue raised in ground no.2(c) is without a prejudice ground that the Amenity Appliances Pvt. Ltd.; A.Y. 2018-19 Provisions of Section 36(1)(va) of the Act read with section 2(24) of the Act do not apply to the employers contribution

Venkata Satya Lakshmi Kantha Rao Grandhi, Guntur vs. Deputy Commissioner of Income Tax, Circle-1(1), Guntur

In the result, appeal filed by the assessee is dismissed

ITA 93/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam27 Feb 2025AY 2021-22

Bench: Shri Laliet Kumar, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.93/Viz/2024 (निर्धारण वर्ा/ Assessment Years: 2021-22) Venkata Satya Lakshmi Kantha Rao V. Dcit, Grandhi, Circle-1(1), Guntur. Guntur. [Pan: Aatpn3851F] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

Section 143(1)Section 234ASection 234CSection 36(1)(va)

Court in the case of Checkmate Services P Ltd vs. CIT (supra) has dealt with the identical issue by interpreting the provisions of section 36(1)(va) and section 43B of the Act and held as under: - “54. In the opinion of this Court, the reasoning in the impugned judgment ... audit reports filed by the assessee where the disallowance was not suomoto made by the assessee. As per the provisions of section 36(1)(va) of the Act, the CPC is within its powers to disallow a wrong claim made by the assessee while filing the return of income which

Gsa Surgical & Medicines Pvt. Ltd., Kolkata vs. ACIT, Cir-6(2), Kolkata.

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

ITA 1174/KOL/2023[2017-18]Status: DisposedITAT Kolkata25 Feb 2025AY 2017-18

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 194JSection 2(24)(x)Section 36(1)(va)Section 40

anआयकर अपील"य अ"धकरण, कोलकाता पीठ “बी’’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH: KOLKATA "ी राजेश कुमार

Mfa Capital Private Limited, Mumbai vs. ACIT- Circle 10(2)(2), Mumbai

Appeal is dismissed as withdrawn

ITA 6403/MUM/2024[2016-17]Status: DisposedITAT Mumbai25 Feb 2025AY 2016-17

Bench: filing return of income u/s.139(1);

For Appellant: Shri Chetna BohraFor Respondent: Shri R. R. Makwana
Section 139(1)Section 143(3)Section 36(1)(va)Section 37(1)

employees contribution to PF and ESIC amounting to INR.54,767/- on account of payment made beyond the due date as referred to in section 36(1)(va) of the Income Tax Act, 1961 (herein after referred as “the Act”) but before filing return of income u/s.139(1); 3. Denying

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

ITA 4385/MUM/2009[2006-07]Status: HeardITAT Mumbai25 Feb 2025AY 2006-07
Section 143(2)Section 143(3)Section 24Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL "G" BENCH, MUMBAI SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

Grasim Industries Ltd ( Corporate Finance Division), Mumbai vs. Addl CIT RG 6(3), Mumbai

ITA 3762/MUM/2009[2006-07]Status: DisposedITAT Mumbai25 Feb 2025AY 2006-07

Bench: the CIT(A). The CIT(A) partly allowed the appeal preferred by the Assessee vide order, dated 18/05/2009. 4. Not being satisfied with the relief granted by the Id. CIT(A), the Assessee has preferred appeal before this Tribunal. The Revenue has also filed cross-appeal challenging the relief granted by the Id. CIT(A).

For Appellant: Shri J. D. Mistry Sr. AdvocateFor Respondent: Shri Kishor Dhule
Section 143(2)Section 143(3)Section 24Section 43B

paid by him. xx xx Analysis and Conclusions 30. The factual narration reveals two diametrically opposed views in regard to the interpretation of section 36(1)(va) on the one hand and proviso to section 43(b) on the other. If one goes by the legislative history of these provisions ... could have been treated only as receipts not amounting to income. When Parliament introduced the amendments in 1988-89, inserting section 36(1)(va) and simultaneously inserting the second proviso of section 43B, its intention was not to treat the disparate nature of the amounts, similarly. As discussed previously

Mussoorie Dehradun Development Authority, Mdda, Transport Nagar Dehradun vs. Assistant Commissioner of Income Tax, National Faceless Assessment Centre

In the result, both appeals of the assessee are dismissed as above

ITA 96/DDN/2023[2018-19]Status: DisposedITAT Dehradun21 Feb 2025AY 2018-19

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 43B

before filing of the ITR. The Ld. AR submitted that the issue involved in this regard was that whether the amendments made in Section 36(1)(va) of the Act by inserting explanation via the Finance Act, 2021 had retrospective applicability. He placed reliance on the decision of Mumbai Tribunal ... case of ANI Integrated Services Ltd. [2024] 162 taxmann.com 889 /207 ITD 91 (Mum)(Trib) wherein it was held as under: "Section 36(1)(va) of the Income-tax Act, 1961 Employee's contributions (PF/ESIC) Assessment year 2019-20 Whether subsequent judgment of Supreme Court in case of Checkmate Services