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“Section 2(24)(x)”

Section References (mined)Section 2Section 2(24)(x)1,421 judgments

M/S. KAMAKSHI JUTE INDUSTRIES LIMITED,KOLKATA vs. ACIT, CIRCLE 1(1),, KOLKATA

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

ITA 3151/KOL/2025[2017-2018]Status: DisposedITAT Kolkata10 Mar 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115JSection 143(2)Section 143(3)Section 2(24)(x)Section 250Section 36(1)(va)

vehemently wrong and unjustified in confirming the addition of Rs. 31,91,258/- made by the Ld. A.O. invoking the provision of section 2(24)(x) r.w.s. 36(1)(va) for the Employees the alleged delay in depositing Contribution to PF & ESI under the relevant Act. Relief Claimed: the addition ... besides interest of ₹7,945/- thereon. Accordingly, the Ld. AO disallowed the above sum u/s 36(1)(va) r.w. section 2(24)(x) of the Act on the ground that the payments were made after the due date of depositing it to the Government account and the same

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 770/RJT/2024[2022-23]Status: DisposedITAT Rajkot09 Mar 2026AY 2022-23

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 769/RJT/2024[2021-22]Status: DisposedITAT Rajkot09 Mar 2026AY 2021-22

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 768/RJT/2024[2020-21]Status: DisposedITAT Rajkot09 Mar 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON ,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 767/RJT/2024[2019-20]Status: DisposedITAT Rajkot09 Mar 2026AY 2019-20

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ACCURATE BUILDCON,RAJKOT vs. DCIT, CC-1, RAJKOT, RAJKOT

ITA 766/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Mar 2026AY 2017-18

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 133ASection 139Section 143(3)Section 147Section 148Section 250

assessee firm from its employees Page 3 of 15 ITA No. 766 to 770/Rjt/2024 Accurate Buildcon to which the provisions of section 2(24)(x) apply, is credited by the assessee to the employee's account in the provident fund after the due date by which the assessee-firm

ZAHEER AHMED SYED,HYDERABAD vs. ACIT., CC-2(2), HYDERABAD

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

ITA 410/HYD/2023[2019-20]Status: DisposedITAT Hyderabad04 Mar 2026AY 2019-20

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 133ASection 139(1)Section 143(3)Section 36(1)(va)Section 80G

आयकर अपीलीय न्यायाधिकरण में, हैदराबाद ‘बी’ बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad श्री विजय

KAUSHAL KUMAR,RANIGANJ vs. ITO, WARD 3(1),, ASANSOL

In the result, both the appeals filed by the Assessee are partly allowed for statistical purposes

ITA 2619/KOL/2025[2020-2021]Status: DisposedITAT Kolkata24 Feb 2026AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

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

court does not find any reason to interfere with the impugned judgment. The appeals are accordingly dismissed.” 5.8 Therefore, under the provisions of section 2(24)(x) of the Act, the contributions from employees are, firstly treated as deemed income and subject to tax in the hand of the employer ... appellant but contributions collected from the employees is obligatory in nature and is considered as deemed income as per provisions of the section 2(24)(x) of the Act. Therefore, in view of the above discussions, the AO is directed to make addition of Rs.22,89,194/- in appellant

KAUSHAL KUMAR,RANIGANJ vs. ITO, WARD 3(1),, ASANSOL

In the result, both the appeals filed by the Assessee are partly allowed for statistical purposes

ITA 2618/KOL/2025[2019-2020]Status: DisposedITAT Kolkata24 Feb 2026AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

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

court does not find any reason to interfere with the impugned judgment. The appeals are accordingly dismissed.” 5.8 Therefore, under the provisions of section 2(24)(x) of the Act, the contributions from employees are, firstly treated as deemed income and subject to tax in the hand of the employer ... appellant but contributions collected from the employees is obligatory in nature and is considered as deemed income as per provisions of the section 2(24)(x) of the Act. Therefore, in view of the above discussions, the AO is directed to make addition of Rs.22,89,194/- in appellant

KANKARIYA AUTOMOBILES PVT LTD,AHILYANAGAR vs. ITO WARD-1, AHILYANAGAR, AHILYANAGAR

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

ITA 1932/PUN/2025[2014-15]Status: DisposedITAT Pune13 Feb 2026AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2014-15

For Appellant: Shri Prasad S BhandariFor Respondent: Shri Deepak Kumar Kedia, JCIT

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 201Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY

MHEALTH VENTURES INDIA P LTD.,,MUMBAI vs. ACIT CIR-15(2)(2), MUMBAI

In the result, the Assessee’s appeal is allowed for statistical purposes

ITA 6175/MUM/2025[2016-17]Status: DisposedITAT Mumbai06 Feb 2026AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankarassessment Year: 2016-17 Mhealth Ventures India Pvt. Assistant Commissioner Ltd., Of Income Tax Circle 729H Raj Legacy, Lbs Marg, Vs. 15(2) (2), Andheri, Mumbai – 400083. Aaykar Bhavan, Maharshi Pan – Aagcm9200P Karve Road, Mumbai – 400020. (Appellant) (Respondent) Present For: Assessee By : Shri Viraj Mehta, Ca (Virtually Appeared) Revenue By : Shri Virabhadra Mahajan, Sr. D.R. Date Of Hearing : 21.01.2026 Date Of Pronouncement : 06.02.2026 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 16.07.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2016-17. 2. In The Instant Case, The Assessing Officer, Vide Assessment Order Dated 28.12.2018 Passed Under Section 143(3) Of The Act, Has Made The Additions Of Rs.3,41,84,927/- & Rs.27,410/- Respectively Under Section 56(2)(Vii)(B) & Section 2(24)(X) As Deemed Income & Added The Same To The Income Of The Assessee. 2 Mhealth Ventures India Pvt. Ltd.

For Appellant: Shri Viraj Mehta, CAFor Respondent: Shri Virabhadra Mahajan, SR. D.R

Section 143(3)Section 2(24)(x)Section 250Section 56(2)(vii)

made the additions of Rs.3,41,84,927/- and Rs.27,410/- respectively under section 56(2)(vii)(b) and section 2(24)(x) as deemed income and added the same to the income of the Assessee. 2 Mhealth Ventures India Pvt. Ltd. 3. The Assessee, being aggrieved, though challenged

DEPUTY COMMISIONER OF INCOME TAX CIRCLE 3(1)(1) AHMEDABAD, AHMEBABAD vs. TECHNO INDUSTRIES, AHMEDABAD

In the result, the appeal filed by the Revenue is partly allowed

ITA 660/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad03 Feb 2026AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyaltechno Industries, Deputy Commissioner Of Vs. Plot No. 613, Phase Iv, Income-Tax, Gidc, Vatva, Circle 3(1)(1), Ahmedabad-382 245 Ahmedabad [Pan : Aacft 1503 D] (Appellant) .. (Respondent) Assessee By : Shri Bandish Soparkar, Ar Respondent By: Shri Abhijit, Sr Dr Date Of Hearing 27.11.2025 Date Of Pronouncement 03.02.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:- This Appeal Has Been Filed By The Revenue Against The Order Dated 22.01.2025 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre, Delhi (“Ld. Cit(A)” For Short), Under Section 250 Of The Income-Tax Act, 1961 (“The Act” For Short), Relating To The Assessment Year 2017- 18. 2. The Revenue Has Raised Following Grounds Of Appeal :- “(1) The Ld. Cit(A) Has Erred In Law & On Facts In Deleting The Addition Of Rs 1,03,00,000/- Made By Ao On Account Of Unsecured Loan Received From Various Lenders U/S. 68 Of It Act, Despite The Fact That The Assessee Had Not Corroborative Evidences Identity Genuineness/Creditworthiness Of The Lenders During Assessment Establish The Proceedings. (2) The Ld. Cit(A) Has Erred In Law & On Facts In Admitting The Additional Evidences During Appellate Proceedings, Without Giving The Opportunity To The Ao As Required By Rule 46A.. (3) The Ld. Cita) Has Erred In Law & On Facts In Deleting The Addition Of Rs.1,66,037/- Made By Ao On Account Of Disallowance Of Interest On Unsecured Loans Paid To Lenders, Despite The Fact That The Assessee Had Not Dcit Vs. Techno Industries Asst. Year : 2017-18 - 2–

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, Sr DR

Section 143(3)Section 250Section 36(1)(va)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

KOTA TRUCKS P.LTD,DELHI vs. ACIT, CIRCLE 14(2), NEW DELHI

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

ITA 2050/DEL/2023[2018-19]Status: DisposedITAT Delhi30 Jan 2026AY 2018-19

Bench: Shri C.N. Prasad & Shri M. Balaganesh[Assessment Year: 2018-19] Kota Trucks P. Ltd. Vs. Acit Bg-223, Sanjay Gandhi Circle -14(2) Transport Nagar, Gt New Delhi Karnal Road, New Delhi- 110042 Pan No.Aadck3550H Appellant Respondent Appellant Sh. Pratap Gupta, Ca (Virtual) Respondent Sh. Om Prakash, Sr. Dr

Section 143(1)Section 2Section 36(1)(va)

crucial. The former forms part of the employers’ income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied i.e., depositing such amount received or deducted from the employee ... could be held as the income of the appellant/assessee under Section 36(1)(va) read with Section 2(24)(x) of the Act of 1961 or not or whether it is subject to the provisions contained in Section 43-B of the of the Act of 1961, was highly debatable

O.K. AUTO COMPONENTS PVT LTD,FARIDABAD vs. DCIT,CENTRAL CIRCLE-1, FARIDABAD

In the result, the appeal is allowed to the extent indicated above leaving the parties to bear their own cost(s)

ITA 3584/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Jan 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 143Section 143(1)Section 143ASection 250Section 36(1)(va)

consequence of above-stated discussion, the prima facie disallowance of impugned contribution towards ESI and EPF under Section 36(1)(va) read with Section 2(24)(x) of the Act of 1961 made by the Assessing Officer under Section 143(1)(a) by order dated 16.12.2021 is hereby set-aside

FUJIYAMA POWER SYSTEMS,PARWANOO vs. ITO PARWANOO, PARWANOO

In the result, the appeal filed by the assessee is allowed, and the penalty of Rs

ITA 977/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh21 Jan 2026AY 2018-19

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

For Appellant: Shri Manoj Kumar, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 143(3)Section 2(24)(x)Section 250Section 270ASection 36(1)(va)Section 68

interest of Rs. 15,300/-; (iii) Addition of Rs. 35,62,089/- on account of delayed payment of employees’ contribution to PF under section 2(24)(x) read with section 36(1)(va); (iv) Addition of Rs. 4,79,88,545/- on account of mismatch of income as per Form

M/S. SOUTH WEST PINNACLE EXPLORATION LIMITED,GURUGRAM vs. ACIT, CIRCLE-24(1), NEW DELHI

In the result, appeal filed by the assessee is allowed

ITA 4076/DEL/2025[2014-15]Status: DisposedITAT Delhi21 Jan 2026AY 2014-15

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarm/S. South West Pinnacle Exploration Limited, Vs. Acit, Circle 24 (1), Plot No.6, 4Th Floor, Sector 44, New Delhi. Gurugram – 122 003 (Haryana). (Pan : Aakcs3608R) (Appellant) (Respondent) Assessee By : Shri I.P. Bansal, Advocate Shri Vivek Bansal, Advocate Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 25.11.2026 Date Of Order : 21.01.2026 O R D E R Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-24, New Delhi [“Ld. Cit (A)”, For Short] Dated 17.06.2025 For The Assessment Year 2014-15. 2. At The Outset, Ld. Ar Of The Assessee Submitted That The Issues Involved In The Present Appeal Are Squarely Covered By Various Decisions & He Heavily Relied Upon The Decision Of The Coordinate Bench In The Case Of Real Innerspring Technologies Pvt. Ltd. Vs. Acit (2025) 174

For Appellant: Shri I.P. Bansal, AdvocateFor Respondent: Shri Manish Gupta, Sr. DR

Section 131(1)(d)Section 142(1)Section 143(2)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘G’: NEW DELHI. BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER and SHRI VIMAL KUMAR

SHETH REALTORS,MUMBAI vs. ACIT-CC-7(1), MUMBAI

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

ITA 5947/MUM/2025[2018-19]Status: DisposedITAT Mumbai19 Jan 2026AY 2018-19

Bench: Shri Arun Khodpiashri Sandeep Singh Karhailsheth Realtors Vasant Oasis, Site Office, Upper Basement, Cts No.345A 1 To 3, 345A 5 To 6, Makwana Road, Marol, Andheri (East), ............... Appellant Mumbai – 400059 Pan: Aavfa3975F

For Appellant: Dr. K ShivramFor Respondent: Shri Vivek Perampurna, CIT-DR

Section 133(6)Section 139(1)Section 2(24)(x)Section 250

employees contribution to PF & ESIC is paid before the filing of IT return than there would not be any disallowance under Section 2(24)(x) r.w.s. 36(1)(va) of I.T. Act. 4. The appellant prays that: a. Disallowances under addition made to Work in Progress for the year

SMT. RAJ BALA,CHANDIGARH vs. DCIT/ACIT CIRCLE 1(1), CHANDIGARH, 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

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 observed that the matter

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

Insurance Act, 1948 (34 of 1948), or any 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 ... provisions of section 2(24)(x) apply, if such sum is credited by the assessee to the employee's account in the relevant fund or funds on or before the due date as specified under the relevant Act. A combined perusal of the above provisions of the Act make

IPF VIKRAM INDIA PRIVATE LIMITED,CHANDIGARH vs. DY. COMMISSIONER OF INCOME TAX, CIRCLE, PANCHKULA, PANCHKULA

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

ITA 1204/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh30 Dec 2025AY 2014-15

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

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 143(3)Section 148

submissions were made by both partners. 9. On merits, the Ld. CIT(A) held that employees’ contribution to PF/ESI is governed by sections 2(24)(x) and 36(1)(va) of the Act and is allowable only if deposited within the due dates prescribed under the respective welfare statutes. Relying

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