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“Section 2(24)(x)”

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

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

Leading authorities on Section 2(24)(x)

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. 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).

CIT v. State Bank of Bikaner & Jaipur
43 Taxmann.com 411 · 2014 · High Court
524
citing judgments

Employee contributions to provident fund, ESI, and other welfare funds, if deposited by the due date for furnishing the return of income under Section 139(1), are allowable as a deduction and cannot be disallowed under Section 36(1)(va) read with Section 2(24)(x) or Section 43B, even if deposited after the due date prescribed by the respective welfare Acts.

Judgments citing Section 2(24)(x)

Reloy Shield Private Limited, New Delhi vs. DCIT, Circle-19(1), Delhi

In the result, appeal of the assessee is dismissed

ITA 972/DEL/2023[2020-21]Status: DisposedITAT Delhi27 Jul 2023AY 2020-21

Bench: Shri Challa Nagendra Prasad, S.M.C.

For Appellant: C. A
Section 143(1)(a)Section 2Section 36(1)(va)Section 43BSection 44A

approach indicated in the ruling in Alom Extrusions. As noticed previously, Alom Extrutions did not consider the fact of the introduction of Section 2(24)(x) or in fact the other provisions of the Act. 52. When Parliament introduced Section 43B, what was on the statute book, was only employer ... Rajasthan High Court). That Parliament intended to retain the separate character of these two amounts, is evident from the use of different language. Section 2(24)(x) too, deems amount received from the employees (whether the amount is received from the employee or by way of deduction authorized

Anuj Yadav Lh Late Shri Dafedar Singh Yadav, Delhi vs. ITO, Ward-49(1), New Delhi

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

ITA 362/DEL/2023[2018-19]Status: DisposedITAT Delhi27 Jul 2023AY 2018-19

Bench: Sh. Chandra Mohan Garg & Sh. Pradip Kumar Kediaanuj Yadav Lh Late Shri Vs. Ito Dafedar Singh Yadav Ward – 49(1) Rzf-769/1, Street No.9, New Delhi Raj Nagar, Part-Ii, Palam Colony, Delhi – 110 045 Pan No. Aarpy 6302 Q (Appellant) (Respondent) Assessee By Shri Krishna Kumar, C.A. Revenue By Shri Vivek Kumar Upadhyay, Sr. D.R. Date Of Hearing: 27.07.2023 Date Of Pronouncement: 27.07.2023

Section 139(1)Section 143(1)Section 2(24)(x)Section 36

Assessment Years prior to Assessment Year 2021-22, belated employees’ contribution are to be reckoned as taxable income of the assessee under Section 2(24)(x) of the Act and the deduction under Section 36(i)(va) of the Act would not be permissible thereon in case of belated payments

Welgrow Hotels Concepts P.Ltd, New Delhi vs. ITO, Ward-27(1), New Delhi

In the result, appeal of the assessee is dismissed

ITA 436/DEL/2023[2018-19]Status: DisposedITAT Delhi26 Jul 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaassessment Year: 2018-19 Welgrow Hotels Concepts P. Ltd., Vs Ito, B-6, Geetanjali Enclave, Ward-27(1), Malviya Nagar, New Delhi. New Delhi – 110 017. Pan: Aaacw5407C (Appellant) (Respondent) Assessee By : Shri S. Krishnan, Advocate Revenue By : Shri Amit Katoch, Sr. Dr Date Of Hearing : 26.07.2023 Date Of Pronouncement : 26.07.2023 Order Per M. Balaganesh, Am: This Appeal In Ita No.436/Del/2023 For Ay 2018-19 Arises Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Hereinafter Referred To As ‘Ld. Cit(A)’, In Short] In Din & Order No.Itba/Nfac/S/250/2022-23/1048179868(1) Dated 22.12.2022 Against The Order Of Assessment Passed U/S 154 R.W.S. 143(1) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 02.12.2020 By The Ld. Assessing Officer, Ward 27(1), New Delhi (Hereinafter Referred To As ‘Ld. Ao’). 2. The Only Issue To Be Decided In This Appeal Is As To Whether The Ld. Cit(A) Was Justified In Confirming The Disallowance Made On Account Of Employee’S Contribution Of Provident Fund & Employee State Insurance In The Facts & Circumstances Of The Instant Case.

For Appellant: Shri S. Krishnan, AdvocateFor Respondent: Shri Amit Katoch, Sr. DR
Section 139(1)Section 154Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

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

DCIT, Central Circle-2, Delhi vs. Mideast Integrated Steels Ltd., Delhi

In the result, appeal of the Revenue for assessment year 2017-18 and appeal of the assessee for assessment year 2017-18 and 2018-19 are dismissed

ITA 2051/DEL/2021[2017-18]Status: DisposedITAT Delhi26 Jul 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Amit Shuklaasstt. Year: 2017-18

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Dilip Singh Kothari, CIT DR DR
Section 144Section 14ASection 2(24)(x)Section 36

Appeals) has erred both in law and on facts in upholding disallowance of Rs. 1,22,36,776/- and by invoking provision of section 2(24)(x) read with section 36(l)(va) of the Act in assessment order dated 12.f2/2019 u/s 144 of the Act. 2. That ... assessee are dismissed. 9. In so far as disallowance of Rs. 1,22,36,776/- by invoking the provision of section 2(24)(x) read with section 36(1)(va) of the Act, admittedly the contribution to the provident fund received from the employees have been made after

Mideast Integrated Steels Ltd., New Delhi vs. ACIT, Central Circle-2, New Delhi

In the result, appeal of the Revenue for assessment year 2017-18 and appeal of the assessee for assessment year 2017-18 and 2018-19 are dismissed

ITA 1569/DEL/2021[2018-19]Status: DisposedITAT Delhi26 Jul 2023AY 2018-19

Bench: Shri G.S. Pannu, Hon’Ble & Shri Amit Shuklaasstt. Year: 2017-18

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Dilip Singh Kothari, CIT DR DR
Section 144Section 14ASection 2(24)(x)Section 36

Appeals) has erred both in law and on facts in upholding disallowance of Rs. 1,22,36,776/- and by invoking provision of section 2(24)(x) read with section 36(l)(va) of the Act in assessment order dated 12.f2/2019 u/s 144 of the Act. 2. That ... assessee are dismissed. 9. In so far as disallowance of Rs. 1,22,36,776/- by invoking the provision of section 2(24)(x) read with section 36(1)(va) of the Act, admittedly the contribution to the provident fund received from the employees have been made after

Mideast Integrated Steels Ltd., New Delhi vs. ACIT, CC-2, New Delhi

In the result, appeal of the Revenue for assessment year 2017-18 and appeal of the assessee for assessment year 2017-18 and 2018-19 are dismissed

ITA 1568/DEL/2021[2017-18]Status: DisposedITAT Delhi26 Jul 2023AY 2017-18

Bench: Shri G.S. Pannu, Hon’Ble & Shri Amit Shuklaasstt. Year: 2017-18

For Appellant: Shri Salil Aggarwal, Sr. AdvocateFor Respondent: Shri Dilip Singh Kothari, CIT DR DR
Section 144Section 14ASection 2(24)(x)Section 36

Appeals) has erred both in law and on facts in upholding disallowance of Rs. 1,22,36,776/- and by invoking provision of section 2(24)(x) read with section 36(l)(va) of the Act in assessment order dated 12.f2/2019 u/s 144 of the Act. 2. That ... assessee are dismissed. 9. In so far as disallowance of Rs. 1,22,36,776/- by invoking the provision of section 2(24)(x) read with section 36(1)(va) of the Act, admittedly the contribution to the provident fund received from the employees have been made after

Starline Workshop, Mumbai vs. ITO WD1(1) (1), Mumbai

ITA 1742/MUM/2021[2018-19]Status: DisposedITAT Mumbai25 Jul 2023AY 2018-19

Bench: The Due Date Of Filing Of Return. 3. The Appellant Prays That The Adjustment Made In The Intimation Order U/S 143(1) Of The Act May Be Deleted. 4. The Appellant Craves Your Honour'S Leave To Add, Alter Or Amend Any Ground Of Appeal At The Time Of Hearing Or Before.”

For Appellant: Shri Ryan Saldanha, A.RFor Respondent: Shri B. Laxmi Kanth, D.R
Section 143(1)Section 2(24)(x)Section 3Section 36Section 36(1)(va)

making adjustment of Rs.4,26,005/- to the return of income on account of income under section 36(1)(va) read with section 2(24)(x) of the Act. 3. The assessee carried the matter before the Ld. CIT(A) by way of filing appeal who has confirmed the addition ... approach indicated in the ruling in Alom Extrusions. As noticed previously, Alom Extrutions did not consider the fact of the introduction of Section 2(24)(x) or in fact the other provisions of the Act. 52. When Parliament introduced Section 43B, what was on the statute book, was only employer

Cargo Motors Gujrat Pvt Ltd, New Delhi vs. ACIT Circle 5(2), New Delhi

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

ITA 239/DEL/2023[2019-20]Status: DisposedITAT Delhi25 Jul 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: NoneFor Respondent: Shri Vivek Kumar Upadhyay, Sr.DR
Section 143(1)Section 143(3)Section 154Section 2(24)(X)Section 36(1)(va)Section 43B

question, belated deposit of employees’ contribution held in trust by the employer assessee are to be reckoned as taxable income under Section 2(24)(X) r.w. Section 43B and deduction under Section 36(1)(va) of the Act would not be permissible. The ld. Sr.DR on behalf of the Revenue

Smg International, New Delhi vs. ITO Ward-30(5), Delhi

In the result, the appeal of the assessee is dismissed

ITA 1500/DEL/2022[2018-19]Status: DisposedITAT Delhi25 Jul 2023AY 2018-19

Bench: Dr. B. R. R. Kumarms. Astha Chandra

For Appellant: NoneFor Respondent: Sh. Amit Shukla, Sr. DR
Section 143(1)(A)Section 2(24)(x)Section 36(1)(va)Section 43Section 43B

dates under the relevant provisions of the Act. The Assessing Officer ruled that by virtue of Section 36(1)(va) read with Section 2(24)(x) of the IT Act, such sums 3 SMG International received by the appellants constituted "income". It was held that those amounts could not have

Ours Youth Club, Vizianagaram vs. Income Tax Officer, Ward-1, Vizianagaram

In the result, appeal of the assessee is allowed

ITA 22/VIZ/2022[2017-18]Status: DisposedITAT Visakhapatnam24 Jul 2023AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.22/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Ours Youth Club Vs. Income Tax Officer 1-19-17, Bc Colony Agraharam Ward-1 Vizianagaram Vijayanagaram [Pan : Aaaao2600H] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri C.Subrahmanyam, ARFor Respondent: Shri O.N.Hari Prasada Rao, DR
Section 139(1)Section 142(1)Section 143(2)Section 143(3)Section 250Section 36(1)(va)

आयकरअपीलीयअधिकरण, धिशाखापटणम “एसएमसी”पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM “SMC” BENCH, VISAKHAPATNAM श्री दुव्वूरु आर एल रेड्डी

M/S. Scantech Laser Pvt. Ltd, Navi Mumbai vs. Income Tax Officer Cir 15(3) (2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 1968/MUM/2021[2018-19]Status: DisposedITAT Mumbai18 Jul 2023AY 2018-19

Bench: The Due Date Of Filing M/S. Scantech Laser Pvt. Ltd Of Return U/S.139(1). In Both The Years Prima Facie Adjustments Have Been Made U/S.143(1) Disallowing The Payment Of Employees Pf & Esic U/S. 36(1)(Va) On The Ground That Same Has Been Paid After Due Date Prescribed Of The Respective Acts.

Section 139(1)Section 143(1)Section 2(24)(x)Section 34(1)(iv)Section 36(1)(iv)Section 36(1)(va)Section 43B

long periods. That Parliament intended to retain the separate character of these two amounts, is evident from the use of different language. Section 2(24)(x) too, deems amount received from the employees (whether the amount is received from the employee or by way of deduction authorized by the statute ... 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 M/s. Scantech Laser Pvt. Ltd conditions spelt by Explanation to section 36(1)(va) are satisfied i.e., depositing such amount received

M/S. Scantech Laser Pvt. Ltd, Navi Mumbai vs. Income Tax Officer Cir 15(3) (2), Mumbai

In the result, appeal of the assessee is dismissed

ITA 1967/MUM/2021[2019-20]Status: DisposedITAT Mumbai18 Jul 2023AY 2019-20

Bench: The Due Date Of Filing M/S. Scantech Laser Pvt. Ltd Of Return U/S.139(1). In Both The Years Prima Facie Adjustments Have Been Made U/S.143(1) Disallowing The Payment Of Employees Pf & Esic U/S. 36(1)(Va) On The Ground That Same Has Been Paid After Due Date Prescribed Of The Respective Acts.

Section 139(1)Section 143(1)Section 2(24)(x)Section 34(1)(iv)Section 36(1)(iv)Section 36(1)(va)Section 43B

long periods. That Parliament intended to retain the separate character of these two amounts, is evident from the use of different language. Section 2(24)(x) too, deems amount received from the employees (whether the amount is received from the employee or by way of deduction authorized by the statute ... 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 M/s. Scantech Laser Pvt. Ltd conditions spelt by Explanation to section 36(1)(va) are satisfied i.e., depositing such amount received

New Light Facility Management, Jlandhar vs. Income Tax Officer Ward -4 (3), Jalandhar

In the result, the appeal of the assessee is dismissed

ITA 140/ASR/2023[2020-21]Status: DisposedITAT Amritsar18 Jul 2023AY 2020-21

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Gunjeet Singh Syal, AdvFor Respondent: Sh. S. M. Surendranath, Sr. DR
Section 143Section 143(1)(a)Section 143(3)Section 154Section 2(24)(x)Section 250Section 36Section 36(1)(va)Section 43B

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) 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

DCIT, Central Circle -15, New Delhi vs. B.L.Kashyap & Sons Ltd, New Delhi

In the result, the appeal of the revenue and cross objection of assessee are allowed for statistical purposes

ITA 2622/DEL/2022[2019-20]Status: DisposedITAT Delhi18 Jul 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Dr. B.R.R. Kumarassessment Year: 2019-20 The Dcit, Centralcircle-15, New Delhi M/S. B.L. Kashyap & Sons Ltd., 409, 4Th Floor, Dlf Tower-A, Jasola, 110055 Vs. New Delhi 110025 Pan Aaacb 0205 F (Appellant) (Respondent) Co No. 174/Del/2022 In Ita No.2622/Del/2022 Assessment Year: 2019-20 M/S. B.L. Kashyap & Sons Ltd., The Dcit, Centralcircle-15, New Delhi 409, 4Th Floor, Dlf Tower-A, Jasola, 110055 New Delhi 110025 Vs. Pan Aaacb 0205 F (Appellant) (Respondent)

For Appellant: Shri Sourav Rohtagi, CA
Section 143(1)Section 2(24)(x)

addition of Rs. 2,63,96,393/- on account of late deposit of employees' contribution to PF & ESI ignoring the provisions of section 2(24)(x) г.w. 36(1)(ra) of IT Act, 1961. 3. Whether on the facts and circumstances of the case

Assistant Commissioner of Income Tax, (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 92/RPR/2020[2013-14]Status: DisposedITAT Raipur18 Jul 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

separately dealt with in different clauses of Section 36 (1). All these establish that Parliament, while introducing Section 36(1)(va) along with Section 2(24)(x), was aware of the distinction between the two types of contributions. There was a statutory classification, under the IT Act, between ... proviso, and observed as follows: “10. “Income” has been defined under Section 2(24) of the Act to include profits and gains. Under Section 2(24)(x), any sum received by the assessee from his employees as contributions to any provident fund/superannuation fund or any fund set up under

Assistant Commissioner of Income Tax (Central)-I, Raipur vs. Mesers Chhattisgarh Steel & Power Limited, Raipur

In the result, appeal of the revenue in ITA No

ITA 91/RPR/2020[2012-13]Status: DisposedITAT Raipur18 Jul 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita Nos.91 & 92/Rpr/2020 "नधा"रण वष" / Assessment Years : 2012-13 & 2013-14 The Assistant Commissioner Of Income Tax, Central Circle-1, Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. Chhattisgarh Steel & Power Limited. 142, Sahid Smarak, G.E Road, Raipur (C.G.) Pan : Aaccc7479G ……""यथ" / Respondent

For Appellant: Ms. Puja Bajaj, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(2)Section 143(3)Section 14ASection 40

separately dealt with in different clauses of Section 36 (1). All these establish that Parliament, while introducing Section 36(1)(va) along with Section 2(24)(x), was aware of the distinction between the two types of contributions. There was a statutory classification, under the IT Act, between ... proviso, and observed as follows: “10. “Income” has been defined under Section 2(24) of the Act to include profits and gains. Under Section 2(24)(x), any sum received by the assessee from his employees as contributions to any provident fund/superannuation fund or any fund set up under

Guntubolu Uma Sai Prasad, Visakhapatnam vs. Assistant Commissioner of Income Tax, Circle-3(1), Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 97/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam17 Jul 2023AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Sri ON Hari Prasada Rao
Section 143(1)Section 36(1)(va)

आयकर अपील"यअ"धकरण, "वशाखापटणम पीठ, "वशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM "ी दु"वू" आर एल

Assistant Commissioner of Income Tax, Circle-3(1), Visakhapatnam vs. Guntubolu Uma Sai Prasad, Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 227/VIZ/2022[2019-20]Status: DisposedITAT Visakhapatnam17 Jul 2023AY 2019-20

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Sri ON Hari Prasada Rao
Section 143(1)Section 36(1)(va)

आयकर अपील"यअ"धकरण, "वशाखापटणम पीठ, "वशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM "ी दु"वू" आर एल

Assistant Commissioner of Income Tax, Circle-3(1), Visakhapatnam vs. Guntubolu Uma Sai Prasad, Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 226/VIZ/2022[2018-19]Status: DisposedITAT Visakhapatnam17 Jul 2023AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Sri ON Hari Prasada Rao
Section 143(1)Section 36(1)(va)

आयकर अपील"यअ"धकरण, "वशाखापटणम पीठ, "वशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL, VISAKHAPATNAM BENCH, VISAKHAPATNAM "ी दु"वू" आर एल

Drishti Lifesaving Pvt. Ltd, Mumbai vs. Centralised Processing Centre, Bengaluru

In the result, all the grounds of appeal of the assessee are dismissed

ITA 1076/MUM/2022[2019-20]Status: DisposedITAT Mumbai14 Jul 2023AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm Drishti Lifesaving Pvt. Ltd. Top Floor, Mehta, Mahal, Cpc, 15, Mathew Road, Vs. Benaluru-560600 Opera House, Mumbai-400 004 (Appellant) (Respondent) Pan No. Aafcd0528C

For Appellant: Dr. K. Shivaram, &For Respondent: Shri Ashok Kumar Ambastha
Section 143Section 143(1)Section 36(1)(va)Section 43B

before the due date of filing of the return of income. According to the provisions of section 36 (1) (va) read with section 2 (24) (x) any sum received by the assessee from his employees as contribution to any provident fund or superannuation fund or any fund set up under ... dues along with his own contribution. Even otherwise, the employees contribution becomes income of the assessee according to the provisions of section 2 (24) (x) of the act. Such sum is granted as deduction only when it is paid before the due date of respective act in terms of provisions