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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)

Star Facilities Management Limited, New Delhi vs. ITO Ward -24(2), New Delhi

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

ITA 1755/DEL/2020[2017-18]Status: DisposedITAT Delhi01 Nov 2021AY 2017-18

Bench: Shri R.K. Pandaassessment Year: 2017-18 Star Facilities Management Limited, Vs. Ito, 115-Ansal Bhawan, Ward-24(2), 16, Kasturba Gandhi Marg, New Delhi. New Delhi. Pan: Aalcs2854C (Appellant) (Respondent) Assessee By : Shri Arta Trana Panda, Advocate Revenue By : Shri Om Prakash, Sr.Dr Date Of Hearing : 01.11.2021 Date Of Pronouncement : 01.11.2021 Order This Appeal Filed By The Assessee Is Directed Against The Order Dated 4Th August, 2020 Of The Cit(A)-8, New Delhi, Relating To Assessment Year 2007-08. 2. The Only Effective Ground Raised By The Assessee In The Instant Appeal Is Regarding The Order Of The Cit(A) In Confirming The Disallowance Of Rs.2,62,984/- On Account Of Delayed Payment Of Employees’ Contribution To Pf & Esi. 3. Facts Of The Case, In Brief, Are That The Assessee Is A Private Limited Company & Filed Its Return Of Income On 30Th July, 2018 Declaring Nil Income. The Return Was Processed On 15Th May, 2019 At Cpc, Bangalore At An Income Of Rs.2,62,980/- By Making An Addition Of Rs.2,62,984/- On Account Of Late Deposit Of Pf/Esi U/S 36(1)(Va) Of The It Act. Before The Cit(A), The Assessee, Relying On Various Decisions, Submitted That The Addition Is Not Justified Since The Assessee Has Deposited The Employees’ Contribution To Pf & Esi Before The Due Date Of Filing The Return Of Income. However, The Ld.Cit(A), Following The Decision Of The Hon’Ble Delhi High Court In The Case Of Cit Vs. Bharat Hotels Ltd., Reported In 410 Itr 417 & Various Other Decisions, Held That The Assessee Is Not Entitled To Deduction U/S 36(1)(Va) Due To Failure On His Part In Depositing The Employees’ Contribution On Or Before The Due Date.

For Appellant: Shri Arta Trana Panda, AdvocateFor Respondent: Shri Om Prakash, Sr.DR
Section 139(1)Section 36(1)(va)

Development Engineers Ltd. (supra) has decided the issue in favour of the assessee holding that no disallowance u/s 36(1)(v) r.w.s. Section 2(24)(x) can be made if the employees’ contribution to PF and ESI are deposited after the due date prescribed under the relevant Acts, but, paid ... filing of the return of income, therefore, respectfully following the decisions cited (supra), I hold that no disallowance u/s 36(1)(v) r.w.s. Section 2(24)(x) can be made in the 4 instant case. Accordingly, the order of the CIT(A) is set aside and the grounds raised

Transzone Logistics (India) Pvt Ltd, New Delhi vs. DCIT CPC, Bangalore

In the result the appeal of the assessee is allowed

ITA 1740/DEL/2020[2018-19]Status: DisposedITAT Delhi29 Oct 2021AY 2018-19

Bench: Sh. Anil Chaturvedi(Through Video Conferencing) Ita Nos.1739 & 1740/Del/2020 (Assessment Years : 2017-18 & 2018-19) Transzone Logistrics Vs. Dcit Cpc (India) Pvt. Ltd. Bangalore House No.259, Front Side First Floor, Shahabad Mohammadpur, New Delhi-110 075 Pan : Aadct 7687 A (Appellant) (Respondent) Assessee By Ms. Gunjan Jain, C.A. Revenue By Ms. Sangeeta Yadav, Sr. D.R. Date Of Hearing: 25.10.2021 Date Of Pronouncement: 29.10.2021 Order Per Anil Chaturvedi, Am:

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

treat belated payment of Employee’s Provident Fund (EPD) and Employee’s State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. It is settled law that when two judgments are available giving different views then the judgment which is in favour

Transzone Logistics (India) Pvt Ltd, New Delhi vs. DCIT CPC, Bangalore

In the result the appeal of the assessee is allowed

ITA 1739/DEL/2020[2017-18]Status: DisposedITAT Delhi29 Oct 2021AY 2017-18

Bench: Sh. Anil Chaturvedi(Through Video Conferencing) Ita Nos.1739 & 1740/Del/2020 (Assessment Years : 2017-18 & 2018-19) Transzone Logistrics Vs. Dcit Cpc (India) Pvt. Ltd. Bangalore House No.259, Front Side First Floor, Shahabad Mohammadpur, New Delhi-110 075 Pan : Aadct 7687 A (Appellant) (Respondent) Assessee By Ms. Gunjan Jain, C.A. Revenue By Ms. Sangeeta Yadav, Sr. D.R. Date Of Hearing: 25.10.2021 Date Of Pronouncement: 29.10.2021 Order Per Anil Chaturvedi, Am:

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

treat belated payment of Employee’s Provident Fund (EPD) and Employee’s State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. It is settled law that when two judgments are available giving different views then the judgment which is in favour

Amandeep Singh Khurana, New Delhi vs. ITO Ward - 30(4), New Delhi

In the result the appeal of the assessee is allowed

ITA 1822/DEL/2020[2018-19]Status: DisposedITAT Delhi27 Oct 2021AY 2018-19

Bench: Sh. Anil Chaturvedi(Through Video Conferencing) Amandeep Singh Khurana Vs. Ito W-71, Gk-1, New Delhi Ward – 30(4) Delhi – 110048 New Delhi Pan : Aajpk 0422 D (Appellant) (Respondent) Assessee By Shri Ashok Khandelwal, C.A. Revenue By Ms. Sangeeta Yadav, Sr. D.R. Date Of Hearing: 27.10.2021 Date Of Pronouncement: 27.10.2021 Order Per Anil Chaturvedi, Am:

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

treat belated payment of Employee’s Provident Fund (EPD) and Employee’s State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. It is settled law that when two judgments are available giving different views then the judgment which is in favour

ACIT- Special Range-1, New Delhi vs. Adm Agro Industries Latur and Vizag Pvt. Ltd., New Delhi

The appeals are hereby dismissed being

ITA 894/DEL/2019[2014-15]Status: DisposedITAT Delhi26 Oct 2021AY 2014-15

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Ms. Soumya Singh, CAFor Respondent: Shri Robin Rawa, Sr. DR
Section 14ASection 194CSection 2(24)(x)Section 254(2)Section 36(1)(va)

ITA No.-892, 893, & 894/Del/2019 ADM Agro Industires. IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘Friday’: NEW DELHI) (THROUGH

ACIT- Special Range-1, New Delhi vs. Adm Agro Industries Latur and Vizag Pvt. Ltd., New Delhi

The appeals are hereby dismissed being

ITA 893/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Oct 2021AY 2013-14

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Ms. Soumya Singh, CAFor Respondent: Shri Robin Rawa, Sr. DR
Section 14ASection 194CSection 2(24)(x)Section 254(2)Section 36(1)(va)

ITA No.-892, 893, & 894/Del/2019 ADM Agro Industires. IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘Friday’: NEW DELHI) (THROUGH

JCIT, Special Range- 1, New Delhi vs. Adm Agro Industries India Pvt. Ltd., Gurgaon

The appeals are hereby dismissed being

ITA 892/DEL/2019[2015-16]Status: DisposedITAT Delhi26 Oct 2021AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

For Appellant: Ms. Soumya Singh, CAFor Respondent: Shri Robin Rawa, Sr. DR
Section 14ASection 194CSection 2(24)(x)Section 254(2)Section 36(1)(va)

ITA No.-892, 893, & 894/Del/2019 ADM Agro Industires. IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH: ‘Friday’: NEW DELHI) (THROUGH

Himachal Futuristic Communications Ltd., New Delhi vs. DCIT, New Delhi

Appeals are disposed of by this common order

ITA 817/DEL/2014[2006-07]Status: DisposedITAT Delhi26 Oct 2021AY 2006-07

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

Himachal Futuristic Communications Ltd., New Delhi vs. DCIT, New Delhi

Appeals are disposed of by this common order

ITA 816/DEL/2014[2005-06]Status: DisposedITAT Delhi26 Oct 2021AY 2005-06

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

DCIT, New Delhi vs. M/S. Himachal Futuristic Communications Ltd., New Delhi

Appeals are disposed of by this common order

ITA 766/DEL/2014[2006-07]Status: DisposedITAT Delhi26 Oct 2021AY 2006-07

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

DCIT, New Delhi vs. M/S. Himachal Futuristic Communications Ltd., New Delhi

Appeals are disposed of by this common order

ITA 765/DEL/2014[2005-06]Status: DisposedITAT Delhi26 Oct 2021AY 2005-06

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

DCIT, New Delhi vs. M/S. Himachal Futuristic Communications Ltd., New Delhi

Appeals are disposed of by this common order

ITA 6226/DEL/2013[2004-05]Status: DisposedITAT Delhi26 Oct 2021AY 2004-05

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

DCIT, New Delhi vs. M/S. Himachal Futuristic Communications Ltd., New Delhi

Appeals are disposed of by this common order

ITA 6225/DEL/2013[2003-04]Status: DisposedITAT Delhi26 Oct 2021AY 2003-04

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

DCIT, New Delhi vs. M/S Himachal Futuristic Communication Ltd., New Delhi

Appeals are disposed of by this common order

ITA 5741/DEL/2013[2002-03]Status: DisposedITAT Delhi26 Oct 2021AY 2002-03

Bench: Shri Kul Bharat & Shri Prashant Maharishi(Through Video Conferencing)

For Appellant: Shri Rakesh Joshi, C. AFor Respondent: Shri Najani [CIT] – D.R
Section 133ASection 143(3)Section 153ASection 80I

officer on account of late deposit of employees contribution towards the respectively provident fund and ESIC account in view of the provisions of Section 2 (24) (x) read with Section 36 (1) (v) (a) of the act. The learned CIT – A has deleted the above disallowances respectfully following the decision ... treat belated payment of Employee's Provident Fund (EPD) and Employee's State Insurance Scheme (ESI) as deemed income of the employer under Section 2(24)(x) of the Act. Appeal is dismissed.” 47. Therefore respectfully following the decision of the honourable Delhi High Court, we uphold the order

Rukmini Polytubes Pvt Ltd, New Delhi vs. DCIT CPC, Bangalore

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

ITA 1855/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Oct 2021AY 2018-19

Bench: Shri R.K. Panda

For Appellant: Shri Suresh Kumar Gupta, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139(1)Section 143Section 143(1)Section 43Section 43B

submitted that the Explanation-2 inserted by Finance Act, 2021 clarifies that the definition of “Income” as provided in Section 2(24)(x) remains unchanged and provision of Section 43B does not apply and deemed to never have been applied for the purpose of determining the due date of payment

Vansh Jain, New Delhi vs. ITO Ward - 28(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 1853/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Oct 2021AY 2018-19

Bench: Shri R.K. Panda

For Appellant: Shri Nem Singh, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 1Section 11Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 2Section 36Section 36(1)(va)

submitted that the Explanation-2 inserted by Finance Act, 2021 clarifies that the definition of “Income” as provided in Section 2(24)(x) remains unchanged and provision of Section 43B does not apply and deemed to never have been applied for the purpose of determining the due date of payment ... legislative intent and objective to treat belated payment of Employees’ Provident Fund & Employees’ State Insurance Scheme as deemed income of the employer under section 2(24)(x) of the I.T. Act, 1961. 10 ITA.No.1853/Del./2020 Mr. Vansh Jain, New Delhi. 7.2. I find the Coordinate Bench of the Tribunal

Aroon Facilitation Management Services Pvt Ltd, New Delhi vs. DCIT CPC, New Delhi

In the result, appeal of the assessee is allowed

ITA 1824/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Oct 2021AY 2018-19

Bench: Shri R.K. Panda

For Appellant: Shri Vijay Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 1Section 11Section 139(1)Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36Section 36(1)(va)Section 43BSection 9

assessee on the ground that this was not paid within prescribed due date and deposited late in the light of provision of Section 2(24)(x) read with section 36(1)(va) of the I.T. Act, 1961 relying upon the information given by the Auditor in Form 3CD. 3.1. Aggrieved ... Rs.9,59,624/-. He accordingly concluded that the CPC is justified in making the addition under section 36(v)(va) read with section 2(24)(x) of the Act for employees’ contribution which was not paid by the due date of the relevant funds and dismissed the appeal filed

Worldwide Facility Management Services Pvt Ltd, New Delhi vs. DCIT CPC, New Delhi

In the result, appeal of the assessee is allowed

ITA 1823/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Oct 2021AY 2018-19

Bench: Shri R.K. Panda

For Appellant: Shri Vijay Gupta, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 1Section 11Section 139(1)Section 143Section 143(1)Section 36Section 36(1)(va)Section 43BSection 9

submitted that the Explanation-2 inserted by Finance Act, 2021 clarifies that the definition of “Income” as provided in Section 2(24)(x) remains unchanged and provision of Section 43B does not apply and deemed to never have been applied for the purpose of determining the due date of payment ... legislative intent and objective to treat belated payment of Employees’ Provident Fund & Employees’ State Insurance Scheme as deemed income of the employer under section 2(24)(x) of the I.T. Act, 1961. 7.2. I find the Coordinate Bench of the Tribunal in the case of Insta Exhibitions

Adma Solution P Ltd, New Delhi vs. ACIT, Bangalore

In the result, appeal of the assessee is allowed

ITA 1800/DEL/2020[2018-19]Status: DisposedITAT Delhi13 Oct 2021AY 2018-19

Bench: Shri R.K. Panda

For Appellant: Shri Suresh Kumar Gupta, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 1Section 11Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 2Section 36Section 36(1)(va)Section 43B

submitted that the Explanation-2 inserted by Finance Act, 2021 clarifies that the definition of “Income” as provided in Section 2(24)(x) remains unchanged and provision of Section 43B does not apply and deemed to never have been applied for the 8 ITA.No.1800/Del./2020 M/s. Adama Solution ... Employees’ State 10 ITA.No.1800/Del./2020 M/s. Adama Solution Pvt. Ltd., New Delhi.. Insurance Scheme as deemed income of the employer under section 2(24)(x) of the I.T. Act, 1961. 7.2. I find the Coordinate Bench of the Tribunal in the case of Insta Exhibitions

Express Roadways P.Ltd, New Delhi vs. ACIT, Circle-8(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 5570/DEL/2017[2013-14]Status: DisposedITAT Delhi11 Oct 2021AY 2013-14

Bench: Sh. Anil Chaturvedi & Sh. Sanjay Garg(Through Video Conferencing) M/S. Express Roadway P. Vs. Acit Ltd., Ed-62-B, Madhuban Circle – 8(2) Chowk, Pitampura, New Delhi New Delhi – 110 088 Pan : Aaace 0255 C (Appellant) (Respondent) Assessee By Shri R. N. Poonia, C.A. Revenue By Shri Jagdish Singh, Sr. D.R. Date Of Hearing: 06.10.2021 Date Of Pronouncement: 11.10.2021 Order Per Anil Chaturvedi, Am:

Section 115JSection 143(3)Section 2(24)(x)Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. ANIL CHATURVEDI, ACCOUNTANT MEMBER AND SH. SANJAY