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“Section 2(24)”

Section References (mined)Section 2Section 2(24)1,946 judgments

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

Leading authorities on Section 2(24)

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. Ponni Sugars & Chemicals Ltd.
306 ITR 392 · 2008 · Supreme Court
577
citing judgments

The "Purpose Test" determines whether an incentive or subsidy is a capital or revenue receipt for income tax purposes. If the incentive's purpose is to enable an assessee to set up a new industry or make investments in capital assets, it is a capital receipt and not taxable.

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 2(24)

Siddhanth Ex - Servicemen Security Services, Vasco vs. DCIT, CPC, Bengaluru

In the result, the appeal of assessee is dismissed

ITA 90/PAN/2022[2018-19]Status: DisposedITAT Panaji21 Sept 2023AY 2018-19

Bench: Shri R.S. Syal & Shri S.S. Viswanethra Ravi

For Appellant: Shri P.R.V. RaghavanFor Respondent: Smt. Ashwini Hosmani
Section 2(24)(x)Section 36(1)(va)

paid within due dates of respective statutes. On careful reading of the said decision of Hon’ble Supreme Court held that Section 2(24)(x) deems amount received from the employees as income and the amounts retained by the employer from out of the employee’s income

Shree Poly Films Private Limited, Visakhapatnam vs. Deputy Commissioner of Income Tax/ Assistent Commissione of Income Tax, Visakhapatnam

In the result, appeal of the assessee is dismissed

ITA 124/VIZ/2022[AY 2019-20]Status: DisposedITAT Visakhapatnam21 Sept 2023

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.124/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Shree Poly Films Private Limited Vs. Dcit/Acit D.No.50-53-11/10 Circle-3(1) Revathi Vihar Apartment Visakhapatnam Seethammadhara, Visakhapatnam [Pan : Aalcs3403K] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: NoneFor Respondent: Shri Madhukar Aves, DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(va)Section 43B

case. 2. On the facts and in the circumstances of the case the elarned Commissioner ought to have appreciated that the provisions of section 2(24)(x) read with section 36(1)(va) and Section 43B of the Income Tax Act, 1961, being late deposit of Employees contribution towards ESIC/EPF

Amaravathi Power Associates, Visakhapatanam vs. DCIT/ACIT, Circle-3(1), Visakhapatanam

In the result, appeal of the assessee is dismissed

ITA 104/VIZ/2022[2019-2020]Status: DisposedITAT Visakhapatnam21 Sept 2023AY 2019-2020

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.104/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2019-20) Amaravathi Power Associates Vs. Dcit/Acit D.No.36-91-30, Ravindra Nagar Circle-3(1) Kancharapalem, Visakhapatnam Visakhapatnam [Pan : Aanfa4444M] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: NoneFor Respondent: Shri Madhukar Aves, DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(va)Section 43B

case. 2. On the facts and in the circumstances of the case the elarned Commissioner ouht to have appreciated that the provisions of section 2(24)(x) read with section 36(1)(va) and Section 43B of the Income Tax Act, 1961, being late deposit of Employees contribution towards ESIC/EPF

Vapi Green Enviro Limited, Vapi vs. Principal Commissioner of Income Tax, Valsad

In the result, various grounds of appeal raised by the assessee are allowed

ITA 387/SRT/2023[2018-19]Status: DisposedITAT Surat21 Sept 2023AY 2018-19

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Vapi Green Enviro Limited, Pr.C.I.T., Valsad. 135, 1St Floor, Via House, G.I.D.C. 301, 3Rd Floor, Palak Vs. Char Rasta, Vapi, Gujarat, Arcade, Shanti Nagar, India-396195. Tithal Road, Pan: Aaacv 8289 P Valsad-396001. Appellant Respondednt

Section 143(3)Section 2(24)Section 254(1)Section 263

Account to meet depreciation on assets acquired out of grants received from Government of India in earlier years prior to the amendment of section 2(24) by inserting clause (xviii) w.e.f. 01.04.2016 and duly covered by exclusion provided thereunder. 6. The Ld. Commissioner of Income Tax (Exemption) has erred ... chargeable under the head Profit & Loss has been shown without two items as income. The income is defined under Section 2(24) of the Act and Finance Act, 2015, new sub-clause (xviii) was inserted w.e.f. 01/04/2016 applicable from A.Y. 2016-17 and as per amendment, assistance of any sort

Promise Manpoer Services Limited, Delhi vs. ITO, Ward-20(2), Delhi

ITA 302/DEL/2023[2018-19]Status: DisposedITAT Delhi20 Sept 2023AY 2018-19

Bench: Shri N.K. Billaiya & Ms. Astha Chandra[A.Y. 2018-19]

For Appellant: NoneFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 2(24)(x)Section 36Section 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

Desein P.Ltd, New Delhi vs. ACIT, Circle-7(1), New Delhi

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

ITA 634/DEL/2023[2019-20]Status: DisposedITAT Delhi18 Sept 2023AY 2019-20

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

For Appellant: Sh. Surender Kumar, CAFor Respondent: Sh. Vivek K. Upadhyay, Sr. DR
Section 143(1)Section 2(24)(x)Section 250Section 250oSection 36(1)(va)Section 37Section 43B

Employee Contribution to Provident Fund (PF)) on account of alleged delayed payment of Employees’ Contribution to PF/ESI by invoking the provisions of Section 2(24)(x) read with section 36(1)(va) of the Act. 3. That the order dated 27.01.2023 passed u/s 250 of the Act by the National

Antony Commercial Vehicle Private Limited, Navi Mumbai vs. DCIT, Circle 15(1)(1), Mumbai

In the result, the appeal by the assessee is dismissed

ITA 1704/MUM/2021[2018 -19]Status: DisposedITAT Mumbai14 Sept 2023

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Shri Manoj Kumar Sinha
Section 143(1)Section 250Section 254(1)Section 254(2)Section 36(1)(iv)Section 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

ACIT, Circle 49(1), Delhi vs. Richa & Co., Delhi

In the result, the appeal of the Revenue is allowed subject to our directions contained in para 8 above

ITA 2354/DEL/2022[2018-19]Status: DisposedITAT Delhi14 Sept 2023AY 2018-19

Bench: Dr. Brr Kumar & Ms. Astha Chandraasstt. Year 2018-19

For Appellant: Shri K V S R Krishna, AdvocateFor Respondent: Shri Vivek Vardhan, Sr. DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 34(1)(iv)Section 36Section 36(1)(va)Section 43B

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 ... long periods. That Parliament intended to retain the 3 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

Deputy Commissioner of Income Tax-1(1), Bhilai vs. Shri Sandeep Surendran Nair, Bhilai

In the result, grounds of appeal raised by Revenue in the present appeal found to be squarely covered in favour of the assessee and thus the same are rejected

ITA 100/RPR/2018[2013-14]Status: DisposedITAT Raipur14 Sept 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं./Ita No.100/Rpr/2018 िनधा"रण वष" /Assessment Year: 2013-14 V. The Dcit-1(1) Shri Sandeep Surendran Bhilai Nair, Prop. M/S. Vasava Engineering Construction, 113-Friends Arcade, Shastri Nagar, Supela, Bhilai [Pan: Aczpn 2865 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" की ओर से/ Appellant By Shri Makarand M. Joshi & Shri Aniruddha Kavimandan, Cas ""थ" की ओर से /Respondent By Shri Satya Prakash Sharma, : Sr. D.R. सुनवाई क" तार"ख/Date Of Hearing 22.08.2023 : घोषणा क" तार"ख /Date Of Pronouncement : 14.09.2023

Section 139Section 143(2)Section 143(3)Section 253Section 43B

case of employee's contribution which were deducted from their income and was held in trust by assessee- employer as per section 2(24)(x), thus, said clause would not absolve assessee employer from its liability to deposit employee's contribution on or before due date as a condition ... deduction Section 36(1)(va), read with sections 2(24)(x) and 438, of the Income-tax Act, 1961 Employee's contributions (PF/ESI) - Whether there is a marked difference between nature and character of assessee-employer's contribution and amounts retained by assessee from out of employee's income

On Door Concepts P Ltd, Bhopal vs. DCIT/ACIT 3(1), Bhopal

In the result, both appeals filed by the assesse in ITANo

ITA 13/IND/2022[2017-18]Status: DisposedITAT Indore14 Sept 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 2(24)(x)Section 34(1)(iv)Section 36Section 36(1)(va)Section 43B

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 ... 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

On Door Concepts P Ltd, Bhopal vs. DCIT/ACIT 3(1), Bhopal

In the result, both appeals filed by the assesse in ITANo

ITA 12/IND/2022[2016-17]Status: DisposedITAT Indore14 Sept 2023AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 143(3)Section 2(24)(x)Section 34(1)(iv)Section 36Section 36(1)(va)Section 43B

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 ... 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

7 Horses Hospitality LLP, Jaipur vs. Income Tax Officer, Ward 1(1) Jaipur, Jaipur

In the result, all the three appeals of the assessee in ITA No

ITA 332/JPR/2023[2019-20]Status: DisposedITAT Jaipur13 Sept 2023AY 2019-20

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

For Appellant: Shri Sharwan Kumar GuptaFor Respondent: Ms. Monisha Choudhary, Addl. CITa
Section 143(1)Section 143(1)(a)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 ... Appeal No.9009 of 2021 [2023] 147 taxmann.com 202 SC)]. The relevant head note is reproduced as under:- Section 36(1)(va), read with section 2(24) and 43B of the Income Tax Act – Employee’s contributions (PF/ESI) – High Court by impugned order held that Tribunal was correct in deleting disallowance

Indian Medical Association, Nagpur vs. CIT(Exemption), Pune

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

ITA 18/NAG/2020[00]Status: DisposedITAT Nagpur12 Sept 2023

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.18/Nag/2020 िनधा"रण वष" / Assessment Year : - Indian Medical Association, The Cit Exemption, Ima Building, Station Vs Pune. Road, Bhandara, Maharashtra – 441904. Pan: Aabti 7140 N Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Kailash Kanojiya – Sr.Dr Date Of Hearing 31/08/2023 Date Of Pronouncement 12/09/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Assessee’S Application For Registration Under Section 12Aa(1)(B)(Ii) Of The Income Tax Act, 1961 Dated 30.11.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Order Passed Is Without Basis & Is Bad In Law. Indian Medical Association [A]

Section 12A

filed by the assessee. The ld.CIT(E) stated the such income of Rs.37.25 lakhs should have been offered by assessee as income under section 2(24)(iia) of the Act. Therefore, ld.CIT(E) concluded that assessee is not eligible for registration under section 12AA of the Act. 4.1 However, assessee

M/S Varsma Engineers Group, 656, Vijay Nagar, Damoh Road, Jabalpur vs. ACIT, Circle 1(1), Jabalpur

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

ITA 90/JAB/2022[2022-21]Status: DisposedITAT Jabalpur11 Sept 2023AY 2022-21

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalem/S. Varsma Engineers Vs Asst. Director Of Group, 656, Vijay Nagar, Income Tax, Cpc, Damoh Road, Jabalpur (M.P.) Bengaluru. Acit, Circle-1(1), Jabalpur. (Appellant) (Respondent) Pan No. Aaefv7885Q Assessee By Shri H.S.Modh, Adv. Revenue By Shri Rajesh Kumar, Sr. Dr Date Of Hearing 11/09/2023 Date Of Pronouncement 11/09/2023 O R D E R Per Om Prakash Kant, A.M.: The Appeal By The Assessee Is Directed Against The Order Dated 03.10.2022 Of Ld. Commissioner Of Income Tax(A)-National Faceless Appeal Centre, Delhi [“In Short The Ld.Cit(A)”] For Assessment Year 2020-21, Raising Following Grounds:-

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

employee’s contribution is concerned , same is considered as income in the hands of the assessee as per section 2(24)(x) of the Act and on payment or deposit of same before due date under relevant Act, 4 | P a g e make the assessee eligible for deduction

Capital Cooperative Thrift & Credit Society Ltd, New Delhi vs. ITO Ward 40(5), New Delhi

In the result, appeal of assessee is partly allowed

ITA 3034/DEL/2019[2013-14]Status: DisposedITAT Delhi11 Sept 2023AY 2013-14

Bench: Sh. Chandra Mohan Garg & Sh. Pradip Kumar Kediacapital Co-Operative Thrift & Vs. Ito Credit Society Ltd. Ward – 40(5) Gd Block, Pitampura, New Delhi New Delhi – 110034

Section 143(3)Section 2(24)Section 56Section 57Section 80PSection 80P(2)(a)Section 80P(2)(c)

under Section 56 of the Act and would be taxable under the head income from other sources and thus would be taxable under Section 2(24) of the Act. 8. In the light of the judgment of Hon’ble Delhi High Court in the case of Mantola Co-operative Thrift

AO, CPC Bengaluru, Karnataka vs. Kamlesh Kumar Singh, Panipat (Haryana)

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

ITA 1458/DEL/2021[2017-2018]Status: DisposedITAT Delhi06 Sept 2023AY 2017-2018

Bench: Sh. Pradip Kumar Kedia & Sh. Yogesh Kumar Usao Vs. Kamlesh Kumar Singh Cpc House No.112, Near Shiv Deep Bengaluru Public School, Refiney Township Karnataka Road, Vpo Dadlana, Panipat Haryana – 132 140 Pan No. Aadck 5251 H (Appellant) (Respondent)

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

Acro Hr Solutions India Pvt.Ltd., New Delhi vs. ACIT, Circle-1(1), Delhi

In the result, appeal of the assessee is dismissed

ITA 83/DEL/2023[2019-20]Status: DisposedITAT Delhi05 Sept 2023AY 2019-20

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaacro Hr Solutions Vs. Acit, India Pvt. Ltd, Circle-1(1), G-10, Hemkunt Delhi Chambers, 89, Nehru Place, New Delhi (Appellant) (Respondent) Pan: Aafca0598M

For Appellant: NoneFor Respondent: Shri. Girish Kohli, Sr. DR
Section 143(3)Section 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

Aruna Gupta, New Delhi vs. ITO, Ward-52(2), Delhi

In the result, appeal of the assessee is dismissed

ITA 228/DEL/2023[2018-19]Status: DisposedITAT Delhi05 Sept 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Anubhav Sharmaaruna Gupta, Vs. Ito, 6715/10, 1St Floor, Ward-52(2), Gali No. 1, Karol Delhi Bagh, Dev Nagar, New Delhi (Appellant) (Respondent) Pan: Assessee By : None Revenue By: Shri Girish Kohli, Sr. Dr Date Of Hearing 28/06/2023 Date Of Pronouncement 05/09/2023

For Appellant: NoneFor Respondent: Shri Girish Kohli, Sr. DR
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

Shri Kamlesh Sen, Bhopal vs. The CIT (A) NFAC, Delhi

In the result, the appeal of assessee is dismissed

ITA 98/IND/2023[2018-19]Status: DisposedITAT Indore05 Sept 2023AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishri Kamlesh Sen Nfac 55, Saluja Complex Delhi Vs. M.P. Nagar-1 Bhopal (Appellant / Assessee) (Revenue) Pan: Bejps 5672C Assessee By Shri Ashish Goyal & Shri N.D. Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 04.09.2023 Date Of Pronouncement 05.09.2023

Section 139(1)Section 143(1)Section 143(3)Section 2(24)(x)Section 246ASection 250Section 34(1)(iv)Section 36Section 36(1)(va)Section 43B

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 ... 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

Bhuneshwar Prasad Sahu, Baloda Bazar, Raipur vs. Income Tax Officer, Ward- Bhatapara, Bhatapara

In the result, the assessee's appeal is allowed in terms of our observations above

ITA 109/RPR/2023[2019-20]Status: HeardITAT Raipur04 Sept 2023AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.109/Rpr/2023 "नधा"रण वष" / Assessment Year : 2019-20 Bhuneshwar Prasad Sahu Main Road, Raseda, Baloda Bazar, Raipur (C.G.) Pan : Bayps7721N .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Khapradih, Bhatapara ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 139(1)Section 143(1)Section 143(1)(a)Section 2(24)(x)Section 36(1)Section 36(1)(va)

employees beyond the prescribed due date as per the respective Acts clearly attracted provisions of section 36(1) (va) read with section 2(24)(x) of the Income Tax Act, 1961 which the AO, CPC was duty bound not to ignore but to consider and make addition/adjustment ... sake of convenience and ready reference, section 36(1) (va) and section 2 (24)(x) of the Income Tax Act, 1961 is reproduced as under, "Other Deductions. 36(1)………………….. (va) any sum received by the assessee from any of his employees to which the provisions of sub-clause