AMICUS AI
Citation Codes
Equivalent Citations
citation codes
Case Number
Disposition
Advocates
Judges
Acts
Are you a practicing lawyer?
Enhance your digital presence and reach by creating a Casemine profile.
Upload pleading to use the new AI search
Cites
Cited by
Citation Codes
Equivalent Citations
citation codes
Case Number
Disposition
Advocates
Judges
Acts
Smart Summary

Summary of Opinion: ITA Nos. 2249/DEL/2022, 2250/DEL/2022, 2197/DEL/2022 & 2293/DEL/2022 (A.Y. 2017-20)

Factual and Procedural Background

This is a consolidated order of the Income Tax Appellate Tribunal, Delhi 'G' Bench (Judicial Member: Kul Bharat; Accountant Member: N.K. Billaiya) pronounced on 09.01.2023 following hearing on 05.01.2023. The bench dealt with three appeals by different assessees (ITA Nos. 2249/DEL/2022, 2250/DEL/2022 and 2197/DEL/2022) against separate orders for assessment years 2018-19, 2017-18 and 2019-20 respectively, and one appeal by the Revenue (ITA No. 2293/DEL/2022) against an order of the NFAC dated 05.08.2022 for A.Y. 2019-20.

The common factual premise in these matters is an admitted delay in depositing employees' contributions to statutory welfare funds (Employees' Provident Fund / Employees' State Insurance) beyond the dates stipulated under the respective enactments. The appeals were heard together because the underlying facts and the legal issue raised were common across the matters.

Legal Issues Presented

  1. Whether employees' contributions (deducted from employees and held in trust) deposited after the due date specified under the relevant enactments can be allowed as a deduction for the employer.
  2. Whether the binding ratio of the Hon'ble Supreme Court in Checkmate Services Pvt Ltd (reported at 143 Taxmann.com 178) applies to return processing under section 143(1) (intimation) as well as to assessments under section 143(3).
  3. Whether the Central Processing Centre (CPC), Bengaluru, while processing returns under section 143(1)(a) of the Income Tax Act, has the power to make disallowances (specifically under clause (iv) of section 143(1)(a)) on account of delayed deposit of employees' contributions.

Arguments of the Parties

Assessee's Arguments

  • The assessee relied on a co-ordinate bench decision (M/s P R Packaging Services, ITA No. 2376/MUM/2022) which, after considering Supreme Court authority, decided the issue in favour of the assessee.
  • It was also argued (identified in the record as "another argument taken before us") that the disallowance made by CPC Bengaluru in the course of return processing under section 143(1) is beyond the scope/powers conferred by section 143(1)(a) of the Income Tax Act and therefore cannot be sustained.

Department/Revenue's Arguments

The opinion does not contain a detailed account of the Department's or Revenue's separate legal arguments beyond the fact that the Revenue preferred an appeal against the NFAC order (seeking reinstatement of disallowance) and that the Revenue's grievance was similar to that of the other appeals.

Table of Precedents Cited

Precedent Rule or Principle Cited For Application by the Court
Checkmate Services Pvt Ltd (reported at 143 Taxmann.com 178) The Supreme Court's analysis distinguishing employer's contribution (Section 36(1)(iv)) from employees' contribution treated as income unless credited by due date (Section 36(1)(va) read with Section 2(24)(x)); holding that employees' contribution deposited after the due date cannot be allowed as deduction. Emphasis on statutory scheme and strict compliance with conditions for deduction. The Tribunal considered this decision binding and applied its ratio to hold that employees' contributions deposited after the due date are not allowable; further held that this ratio is applicable to intimation under section 143(1) as well as to assessments under section 143(3).
M/s P R Packaging Services (ITA No. 2376/MUM/2022) Coordinate bench decision which, according to the parties, applied the Supreme Court's decision and decided the issue in favour of the assessee (i.e., against disallowance). The Tribunal reviewed this decision and found it to have relied on Kalpesh Synthetics; however, this bench distinguished P R Packaging Services as it considered that the co-ordinate bench had ignored the binding ratio of the Supreme Court (Checkmate).
Kalpesh Synthetics Pvt Ltd, 195 ITD 142 The co-ordinate bench held that CPC Bengaluru cannot override a binding decision of the jurisdictional High Court while making disallowance under section 143(1)(a)(iv); reading section 143(1)(a) down where audit report conflicts with binding jurisdictional High Court law. The Tribunal noted that P R Packaging relied on Kalpesh Synthetics but observed that Kalpesh was based on interpretation and binding decision of the jurisdictional High Court; this bench nonetheless refused to brush aside the Supreme Court ratio and followed Checkmate.
Alom Extrusions (citation referenced in the opinion) Considered impact of deletion of second proviso to Section 43B; held that omission was curative and if employer deposited dues before filing return deduction would be available. The Tribunal noted that Alom Extrusions did not consider Sections 2(24)(x) and 36(1)(va) and therefore its reasoning was not determinative for the present issue which hinges on those provisions and the Supreme Court's analysis.
Eagle Flask Industries Ltd v. Commissioner of Central Excise (2004 Supp (4) SCR 35) Principle that deductions under tax statutes must be strictly construed and conditions for deduction must be strictly complied with. Cited to support the proposition that taxing statutes/exemptions/deductions are to be construed strictly and that conditions for claiming deduction must be met.
State of Jharkhand v. Ambay Cements (citation referenced in the opinion) Rule that exemption or exception provisions in a taxing statute are to be strictly construed and mandatory conditions enforced; failure to comply with mandatory conditions results in denial of exemption/deduction. Cited in the chain of authority supporting strict compliance with conditions for claiming exemption/deduction and the mandatory nature of such statutory requirements.
Allied Motors (P) Limited (referenced) Referenced as a three-Judge Bench precedent relevant to retrospective operation discussion in Alom Extrusions (no specific rule stated beyond the reference in the opinion). Referenced in the Tribunal's recounting of prior case law considered by Alom Extrusions; not relied upon independently in this decision beyond the cited context.

Court's Reasoning and Analysis

The Tribunal's reasoning progressed through the following steps (as recorded in the opinion):

  1. Admitted factual premise: there was a delay in depositing employees' contributions to PF/ESI beyond the dates mandated by the respective welfare enactments. This fact was undisputed across the matters.
  2. Identification of precedent conflict: the bench observed that a co-ordinate bench (P R Packaging Services) had decided in favour of the assessee, relying on Kalpesh Synthetics, but the Tribunal considered that decision to have not given an independent finding and to have relied upon the jurisdictional High Court interpretation underpinning Kalpesh.
  3. Primacy of the Supreme Court decision: the Tribunal held that the matter is not res integra because the Hon'ble Supreme Court in Checkmate Services Pvt Ltd has settled the issue by a binding decision. The Tribunal quoted and analysed the Supreme Court's relevant observations showing statutory distinctions between employer's contribution (Section 36(1)(iv)) and employees' contribution (Section 36(1)(va) read with Section 2(24)(x)), and that employees' contributions must be credited/deposited on or before the due date to be allowable; otherwise they are to be treated as income and not deductible.
  4. Rejection of narrow contextual limitation: the Tribunal rejected the submission that the Supreme Court's decision applies only to assessments framed under section 143(3) and not to processing/intimation under section 143(1). The Tribunal reasoned that the Supreme Court's ratio — that employees' contribution deposited after the due date cannot be allowed as deduction — cannot be brushed aside merely because the Supreme Court decision arose in the context of assessments under section 143(3).
  5. Power of CPC under section 143(1): the Tribunal examined the scope of section 143(1)(a) (including its sub-clauses such as (iv)) and concluded that adjustments indicated therein (including disallowance of expenditure indicated in the audit report but not taken into account in the return) are within the scope of CPC's processing powers. In light of the Supreme Court's reasoning, the Tribunal held that an adjustment under section 143(1) for delayed deposit is not beyond CPC's powers.
  6. Prevention of discriminatory outcome: the Tribunal emphasised that a contrary, narrow interpretation (i.e., confining the Supreme Court ratio only to section 143(3) assessments and not to section 143(1) processing) would create anomalous discrimination among taxpayers — some taxpayers processed by CPC under section 143(1) could escape disallowance for delayed deposit while others subject to scrutiny under section 143(3) would face disallowance. The Tribunal found such an outcome contrary to legislative intent and the Supreme Court's reasoning.
  7. Conclusion applying binding authority: accordingly, and respectfully following the Supreme Court, the Tribunal concluded that the ratio in Checkmate applies equally to intimation under section 143(1). The Tribunal therefore held that employees' contributions deposited after the due date are not allowable and that CPC's adjustment was not beyond its powers.

Holding and Implications

Core Ruling: All three appeals of the assessees are dismissed and the appeal of the Revenue is allowed.

Direct consequences:

  • The three assessee appeals (ITA Nos. 2249/DEL/2022, 2250/DEL/2022 and 2197/DEL/2022) were dismissed, meaning the disallowances made (or confirmed) by the Assessing Officer / CPC for delayed deposit of employees' contributions stand upheld by this Tribunal bench in these matters.
  • The Revenue's appeal (ITA No. 2293/DEL/2022) was allowed, meaning the NFAC order (which had deleted the disallowance) was set aside in favour of the Revenue.

Broader implications and precedent:

  • The Tribunal explicitly followed and applied the binding ratio of the Hon'ble Supreme Court (Checkmate Services Pvt Ltd) to the processing of returns under section 143(1) — thereby treating that ratio as applicable beyond assessments under section 143(3).
  • The opinion does not claim to lay down a new precedent supplanting Supreme Court authority; rather, it applies the Supreme Court's ratio and distinguishes the contrary co-ordinate bench decisions that were relied on by the assessees.

Order pronounced in open court on 09.01.2023.

Bench: Shri Kul Bharat (Judicial Member) and Shri N.K. Billaiya (Accountant Member).

To access the original judgment, please Sign In or Subscribe.

    B4S Solutions P.Ltd, New Delhi v. ACIT, Circle-4(2), New Delhi

    IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI 'G' BENCH,

    NEW DELHI

    BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER, AND

    SHRI KUL BHARAT, JUDICIAL MEMBER

    ITA No. 2249/DEL/2022 [A.Y. 2018-19] Savleen Kaur Vs. The I.T.O W/Z-154-A, Top Floor Ward -54(4) Virender Nagar Delhi

    Tilak Nagar, New Delhi

    PAN: BMHPK 0447 F

    Assessee By : Shri Sandeep Jain, CA Shri J.P. Sharma, CA

    Department By : Ms. Maninder Kaur, Sr. DR ITA No. 2250/DEL/2022 [A.Y. 2017-18] Krishan Pal Vs. The Dy. C.I.T. 8-A, Shiv Mandir, CPC

    Govind Mohalla Bengaluru

    Haidarpur Village, Delhi

    PAN: AHZPP 4577 F

    Assessee By : Shri Ajit Jha, Adv Department By : Ms. Maninder Kaur, Sr. DR

    1

    2

    ITA No. 2197/DEL/2022 [A.Y. 2019-20] B4S Solutions Pvt Ltd Vs. The A.C.I.T. R -2, 2ndFloor, Raj Kunk Circle - 4(2) Rajnagar, Ghaziabad New Delhi Uttar Pradesh

    PAN: AABCB 4705 D

    Assessee By : Shri Akhilesh Kumar, Adv Department By : Ms. Maninder Kaur, Sr. DR ITA No. 2293/DEL/2022 [A.Y. 2019-20] The A.C.I.T. Vs. Aero Club

    Circle - 49(1) 867, Joshi Road New Delhi Karol Bagh, New Delhi

    PAN: AAFFA 1530 L

    (Applicant) (Respondent) Assessee By : Shri R.K. Kapoor, Adv Department By : Ms. Maninder Kaur, Sr. DR

    Date of Hearing : 05.01.2023 Date of Pronouncement : 09.01.2023

    3

    ORDER

    PER N.K. BILLAIYA, ACCOUNTANT MEMBER:-

    The above captioned three appeals by different assessees are preferred against three separate orders pertaining to Assessment Years 2018-19, 2017-18 and 2019-20 respectively. The appeal of the Revenue is preferred against the order of the NFAC dated 05.08.2022 pertaining to Assessment Year 2019-20

    2. Since the underlying facts in the issues are common and the grievance of the assessees/Revenue are identical in all the four appeals, all these appeals were heard together and are disposed of by this common order for the sake of convenience and brevity.

    3. The common grievance in all the appeals by the assessees/Revenue relates to the additions/disallowances made on account of delayed deposit of Employees Contribution to ESI/PF and in Revenue's appeal, the grievance is similar, though the ld. CIT(A) has deleted the disallowance whereas in the other appeals, the ld. CIT(A) has confirmed the disallowance.

    4

    4. The undisputed fact in the captioned appeals is that there was a delay in depositing the employees' contribution and the contribution has been deposited beyond the date stipulated under the relevant Fund Act.

    5. Though the quarrel is no more res integra, as it has been settled by the decision of the Hon'ble Supreme Court in the case of Checkmate Services Pvt Ltd 143 Taxmann.com 178. But, before us, the decision of the co-ordinate bench at Mumbai has been placed in the case of PR Packaging Service in ITA No. 2376/MUM/2022 and it has been seriously argued that the co-ordinate bench has considered the decision of the Hon'ble Supreme Court and yet decided the quarrel in favour of the assessee and against the Revenue.

    6. Another argument taken before us is that the disallowance made by the CPC Bengaluru while processing the return u/s 143(1) of the Act is beyond the scope of provisions of section 143(1(a) of the Act and, therefore, cannot be sustained.

    5

    7. We have carefully perused the decision of the co-ordinate bench in the case of M/s P R Packaging Services [supra]. We find that the co- ordinate bench has not given any independent finding but has simply relied upon another decision of the co-ordinate bench in the case of Kalpesh Synthetics Pvt Ltd 195 ITD 142 wherein the co-ordinate bench has based its decision on the interpretation and binding decision of the Hon'ble Jurisdictional High Court. In the case of Kalpesh Synthetics Pvt Ltd [supra], the Tribunal has held that the CPC Bengaluru cannot override the binding decision of the Hon'ble Bombay High Court while making the impugned disallowance on account of delay in the deposit of employees' contribution to PF/ESI.

    8. It would be apt to refer to the relevant part of the decision of the Tribunal in the case of Kalpesh Synthetics [supra] followed in P R Packaging Service [supra] wherein it has been held as under:

    "8. When the law enacted by the legislature has been construed in a particular manner by the Hon'ble jurisdictional High Court, it cannot be open to anyone in the jurisdiction of that Hon'ble High Court to read any other manner than as read by the Hon'ble jurisdictional High Court. The views expressed by the tax auditor in such a situation, cannot be reason enough to disregard the

    6

    binding views of the Hon'ble jurisdictional Court. To that extent, the provisions of section 143(1)(a)(iv) must be read down. What essentially follows is the adjustments under section 143(1)(a) in respect of" disallowance of expenditure indicated in the audit report but not taken into account in computing the total income in the return" is to be read as, for example, subject to the rider "except in a situation in which the audit report has taken a stand contrary to the law laid down by Hon'ble Courts above". That is where the quasi judicial exercise of dealing with the objections of the assessee against proposed adjustments under section 143(1), assumes critical importance in the processing of returns, also important to bear in mind the fact that what constitutes jurisdictional High Court will essentially depend upon the location of the jurisdictional Assessing Officer. While dealing with jurisdiction for the appeals, rule 11(1) of the Central Processing of Returns Scheme, 2011 states that "Where a return is processed at the Centre, the appeal proceedings relating to the processing of the return shall lie with Commissioner of Income Tax (Appeals) [CIT(A)] having jurisdiction over the jurisdictional Assessing Officer" Then situs of the CPC or the Assessing Office CPC is thus irrelevant for the purpose of ascertaining the jurisdictional High Court. Therefore, in the present case, whether the CPC is within the jurisdiction of Hon'ble Bombay High Court or not, as for the regular Assessing Officer of the assessee and the assessee are located in the jurisdiction of Hon'ble

    7

    Bombay High Court, the jurisdictional High Court, for all matters pertaining to the assessee, will be Hon'ble Bombay High Court. In our considered view, it cannot be open to the Assessing Officer CPC to take a view contrary to the view taken by the Hon'ble jurisdictional High Court- more so when his attention was specifically invited to binding judicial precedents in this regard. For this reason also, the inputs in question in the tax audit report cannot be reason enough to make the impugned disallowance. The assessee must succeed for this reason as well."

    9. With our utmost respect to the findings of the co-ordinate bench [supra], we are of the considered view that the co-ordinate bench has ignored the binding ratio decidendi of the Hon'ble Supreme Court in the case of Checkmate Services Pvt Ltd [supra]. It would be pertinent to refer to the most relevant observations of the Hon'ble Supreme Court on the impugned quarrel which read as under:

    "32. The scheme of the provisions relating to deductions, such as Sections 32 - 37, on the other hand, deal primarily with business, commercial or professional expenditure, under various heads (including depreciation). Each of these deductions, has its contours, depending upon the expressions used, and the conditions that are to be met. It is therefore necessary to bear in mind that specific enumeration of deductions, dependent upon fulfillment of particular conditions, would qualify as allowable deductions: failure by the assessee to comply with those conditions, would render the claim vulnerable to rejection.

    8

    In this scheme the deduction made by employers to approved provident fund schemes, is the subject matter of Section 36 (iv). It is noteworthy, that this provision was part of the original IT Act; it has largely remained unaltered. On the other hand, Section 36(1)(va) was specifically inserted by the Finance Act, 1987, w.e.f. 01-04-1988. Through the same amendment, by Section 3(b), Section 2(24) - which defines various kinds of

    "income" - inserted clause (x). This is a significant amendment, because Parliament intended that amounts not earned by the assessee, but received by it, - whether in the form of deductions, or otherwise, as receipts, were to be treated as income. The inclusion of a class of receipt, i.e., amounts received (or deducted from the employees) were to be part of the employer/assessee's income. Since these amounts were not receipts that belonged to the assessee, but were held by it, as trustees, as it were, Section 36(1)(va) was inserted specifically to ensure that if these receipts were deposited in the EPF/ESI accounts of the employees concerned, they could be treated as deductions. Section 36(1)(va) was hedged with the condition that the amounts/receipts had to be deposited by the employer, with the EPF/ESI, on or before the due date. The last expression "due date" was dealt with in the explanation as the date by which such amounts had to be credited by the employer, in the concerned enactments such as EPF/ESI Acts. Importantly, such a condition (i.e., depositing the amount on or before the due date) has not been enacted in relation to the employer's contribution (i.e., Section

    36(1)(iv)).

    33. The significance of this is that Parliament treated contributions under Section 36(1)(va) differently from those under Section 36(1)(iv). The latter (hereinafter, "employers' contribution") is described as "sum paid by the assessee as an

    9

    employer by way of contribution towards a recognized provident fund". However, the phraseology of Section 36(1)(va) differs from Section 36(1)(iv). It enacts that "any sum received by the assessee from any of his employees to which the provisions of sub-clause (x) of clause (24) of section 2 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." The essential character of an employees' contribution, i.e., that it is part of the employees' income, held in trust by the employer is underlined by the condition that it has to be deposited on or before the due date.

    34. It is therefore, manifest that the definition of contribution in Section 2 (c) is used in entirely different senses, in the relevant deduction clauses. The differentiation is also evident from the fact that each of these contributions is 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 the two.

    35. It is instructive in this context to note that the Finance Act, 1987, introduced to Section 2(24), the definition clause (x), with effect from 1 April 1988; it also brought in Section 36(1)(va). The memorandum explaining these provisions, in the Finance Bill, 1987, presented to the Parliament, is extracted below:

    "Measures of penalising employers mis-utilising contributions to the provident fund or any funds set up under the provisions of the Employees State Insurance Act, 1948, or any other fund for the welfare of employees -

    10

    12.1. The existing provisions provide for a deduction in respect of any payment by way of contribution to the provident fund or a superannuation fund or any other fund for welfare of employees in the year in which the liabilities are actually discharged (Section 43B). The effect of the amendment brought about by the Finance act, is that no deduction will be allowed in the assessment of the employer, unless such contribution is paid into the fund on or before the due date. "Due date" means the date by which an employer is required to credit the contribution to the employees account in the relevant fund or under the relevant provisions of any law or term of the contract of service or otherwise. (Explanation to Section 36 (1) of the Finance Act)

    12.2. In addition, contribution of the employees to the various funds which are deducted by the employer from the salaries and wages of the employees will be taxed as income within brackets insertion of new [clause (x) in clause (24) of Section 2] of the employer, if such contribution is not credited by the employer in the account of the employee in the relevant fund by the due date. Where such income is not chargeable to tax under the head "profits and gains of business or profession" it will be assessed under the head "income from other sources."

    XXXXXX

    11

    44. There is no doubt that in Alom Extrusions, this court did consider the impact of deletion of second proviso to Section 43B, which mandated that unless the amount of employers' contribution was deposited with the authorities, the deduction otherwise permissible in law, would not be available. This court was of the opinion that the omission was curative, and that as long as the employer deposited the dues, before filing the return of income tax, the deduction was available.

    45. A reading of the judgment in Alom Extrusions, would reveal that this court, did not consider Sections 2(24)(x) and 36(1)(va). Furthermore, the separate provisions in Section 36(1) for employers' contribution and employees' contribution, too went unnoticed. The court observed inter alia, that:

    "15. …It is important to note once again that, by Finance Act, 2003, not only the second proviso is deleted but even the first proviso is sought to be amended by bringing about an uniformity in tax, duty, cess and fee on the one hand vis-a-vis contributions to welfare funds of employee(s) on the other. This is one more reason why we hold that the Finance Act, 2003, is retrospective in operation. Moreover, the judgement in Allied Motors (P) Limited (supra) is delivered by a Bench of three learned Judges, which is binding on us. Accordingly, we hold that Finance Act, 2003 will operate retrospectively with effect from 1st April, 1988 [when the first proviso stood inserted]. Lastly, we may point out the hardship and the invidious discrimination which would be caused to the assessee(s) if the contention of the Department is to be accepted that Finance Act, 2003, 2003, to the above extent, operated prospectively. Take an example - in the present case, the respondents have deposited the

    12

    contributions with the R.P.F.C. after 31st March [end of accounting year] but before filing of the Returns under the Income Tax Act and the date of payment falls after the due date under the Employees' Provident Fund Act, they will be denied deduction for all times. In view of the second proviso, which stood on the statute book at the relevant time, each of such assessee(s) would not be entitled to deduction under Section 43B of the Act for all times. They would lose the benefit of deduction even in the year of account in which they pay the contributions to the welfare funds, whereas a defaulter, who fails to pay the contribution to the welfare fund right upto 1st April, 2004, and who pays the contribution after 1st April, 2004, would get the benefit of deduction under Section 43B of the Act. In our view, therefore, Finance Act, 2003, to the extent indicated above, should be read as retrospective. It would, therefore, operate from 1st April, 1988, when the first proviso was introduced. It is true that the Parliament has explicitly stated that Finance Act, 2003, will operate with effect from 1st April, 2004. However, the matter before us involves the principle of construction to be placed on the provisions of Finance Act, 2003".

    XXXX

    48. One of the rules of interpretation of a tax statute is that if a deduction or exemption is available on compliance with certain conditions, the conditions are to be strictly complied with. Eagle Flask Industries Ltd Vs. Commissioner of Central Exercise 2004 Supp (4) SCR 35. This rule is in line with the general principle that taxing statutes are to be construed strictly, and that there is no room for equitable considerations.

    13

    49. That deductions are to be granted only when the conditions which govern them are strictly complied with. This has been laid down in State of Jharkhand v Ambay Cements as follows:

    "23…. In our view, the provisions of exemption clause should be strictly construed and if the condition under which the exemption was granted stood changed on account of any subsequent event the exemption would not operate.

    24. In our view, an exception or an exempting provision in a taxing statute should be construed strictly and it is not open to the court to ignore the conditions prescribed in the industrial policy and the exemption notifications.

    25. In our view, the failure to comply with the requirements renders the writ petition filed by the respondent liable to be dismissed. While mandatory rule must be strictly observed, substantial compliance might suffice in the case of a directory rule.

    26. Whenever the statute prescribes that a particular act is to be done in a particular manner and also lays down that failure to comply with the said requirement leads to severe consequences, such requirement would be mandatory. It is the cardinal rule of interpretation that where a statute provides that a particular thing should be done, it should be done in the manner prescribed and not in any other way. It is also settled rule of interpretation that where a statute is penal in character, it must be strictly construed and followed. Since the requirement, in the instant case, of obtaining prior permission is

    14

    mandatory, therefore, non-compliance with the same must result in cancelling the concession made in favour of the grantee, the respondent herein."

    XXXX

    53. The distinction between an employer's contribution which is its primary liability under law - in terms of Section 36(1)(iv), and its liability to deposit amounts received by it or deducted by it (Section 36(1)(va)) is, thus 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 on or before the due date. In other words, there is a marked distinction between the nature and character of the two amounts - the employer's liability is to be paid out of its income whereas the second is deemed an income, by definition, since it is the deduction from the employees' income and held in trust by the employer.

    54. That, however, cannot apply in the case of amounts which are held in trust, as it is in the case of employees' contributions- which are deducted from their income. They are not part of the assessee employer's income, nor are they heads of deduction per se in the form of statutory pay out. They are others' income, monies, only deemed to be income, with the object of ensuring that they are paid within the due date specified in the particular law. They have to be deposited in terms of such welfare enactments. It is upon deposit, in terms of those enactments and on or before the due dates mandated by such concerned law, that the amount which is otherwise retained, and deemed an income, is treated as a deduction. Thus, it is an essential condition for

    15

    the deduction that such amounts are deposited on or before the due date."

    10. In our understanding, the aforementioned binding observations of the Hon'ble Supreme Court cannot be brushed aside simply because the decision was rendered in the context where the assessment was framed u/s 143(3) and not u/s 143(1)(a) of the Act. In our considered opinion, the decision of the Hon'ble Supreme Court is in the context of allowability of deposit of PF/ESI after due date specified in the relevant Act.

    11. The Hon'ble Supreme Court has categorically held that the employees' contribution deposited after respective due date cannot be allowed as deduction, and, therefore, it would be incorrect to say that the decision of the Hon'ble Supreme Court is applicable only in the case of an assessment farmed u/s 143(3) of the Act. In our considered view, the ratio decidendi is equally applicable for the intimation framed u/s 143(1) of the Act.

    12. Now coming to the challenge that the impugned adjustment is beyond the powers of the CPC Bengaluru u/s 143(1) of the Act is also not correct. In light of the aforementioned decision of the Hon'ble

    16

    Supreme Court [supra], as mentioned elsewhere, it cannot be stated that the impugned adjustment u/s 143(1) of the Act is beyond the powers of the CPC, Bengaluru.

    13. The provisions of section 143(1)(a) read as under:

    "143(1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of Section 143, such return shall be processed in the following manner, namely;-

    (a) The total income or loss shall be computed after making the following adjustments, namely;-

    (i) Any arithmetical error in the return;

    (ii) An incorrect claim, if such incorrect claim is apparent from any information in the return;

    (iii) Disallowance of loss claimed, if return of the previous year for which set off of loss is claimed was furnished beyond the due date specified under sub-section (1) of section 139;

    (iv) Disallowance of expenditure [or increase in income] indicated in the audit report but not taken into account in computing the total income in the return;

    17

    (v) Disallowance of deduction claimed under [section 10AA or under any of the provisions of Chapter VI-A under the heading "C.-Deductions in respect of certain income", if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or

    (vi) Addition of income appearing in Form 26AS or Form 16A or Form 16 which has not been included in computing the total income in the return;"

    12. A perusal of the afore-stated provisions show that at every stage in sub-section (1) of the Act, the return submitted by the assessee forms the foundation, with respect to which, if any of the inconsistencies referred to in various sub-clauses are found, appropriate adjustments are to be made. It is an open secret that hardly 3 to 5% of the returns are selected for scrutiny assessment, out of which, more than 50% are because of AIR Information under CASS and the Assessing Officer cannot go beyond the reasons for scrutiny selection and such cases are called Limited Scrutiny cases and only the remaining returns are taken up for complete scrutiny u/s 143(3) of the Act.

    18

    13. Meaning thereby, that exercise of power under sub-section (2) of section 143 of the Act leading to the passing of an order under sub- section (3) thereof, is to be undertaken where it is considered necessary or expedient to ensure that the assessee has not understated income or has not computed excessive loss, or has not under paid the tax in any manner,

    14. If any narrow interpretation is given to the decisions of the Hon'ble Supreme Court in the case of Checkmate Services Pvt Ltd [supra], it would not only defeat the very purpose of the enactment of the provisions of section 143(1) of the Act but also defeat the very purpose of the Legislators and the decision of the Hon'ble Supreme Court would be made redundant because there would be discrimination and chaos, in as much as, those returns which are processed by the CPC would go free even if the employees' contribution is deposited after the due date and in some cases the employer may not even deposit the employees' contribution and those whose returns have been scrutinized and assessed u/s 143(3) of the Act would have to face the disallowance.

    19

    15. This can neither be the intention of the Legislators nor the decision of the Hon'ble Supreme Court has to be interpreted in such a way so as to create such discrimination amongst the tax payers. Such interpretation amounts to creation of class [tax payer] within the class [tax payer] meaning thereby that those tax payers who are assessed u/s 143(3) of the Act would have to face disallowance because of the delay in deposit of contribution and those tax payers who have been processed and intimated u/s 143(1) of the Act would go scot- free even if there is delay in deposit of contribution and even if they do not deposit the contribution.

    16. We are of the considered view that the ratio decidendi of the Hon'ble Supreme Court is equally applicable to the intimation u/s 143(1) of the Act and, therefore, the decision of the co-ordinate bench relied upon by the assessee is distinguishable. Therefore, respectfully following the binding decision of the Hon'ble Supreme Court [supra], all the three appeals of the assessee are dismissed and that of the revenue is allowed.

    20

    17. In the result, all the three captioned appeals of the assessee in ITA Nos. 2249/DEL/2022, 2250/DEL/202 and 2197/DEL/2022 are dismissed whereas the appeal of the Revenue in ITA No. 2293/DEL/2022 is allowed.

    The order is pronounced in the open court on 09.01.2023.

    Sd/- Sd/-

    [KUL BHARAT] [N.K. BILLAIYA]

    JUDICIAL MEMBER ACCOUNTANT MEMBER

    Dated: January, 2023. VL/

    Copy forwarded to:

    1. Appellant

    2. Respondent

    3. CIT

    4. CIT(A)

    5. DR

    Asst. Registrar, ITAT, New Delhi

    Use AI to get other relevant cases.

    Comments

    B4S Solutions P.Ltd, New Delhi v. ACIT, Circle-4(2), New Delhi
    (Jan 9, 2023)