This document reviews the tribunal case ITA 1639/DEL/2021 concerning Randhir Rana’s appeal against the ADIT, CPC Ward2(2), Haryana. The case centers on the disallowance of Rs.3,95,788, allegedly due to delayed contributions to employees’ Provident Fund (EPF) and State Insurance (ESI) for the assessment year 2019-2020.
Randhir Rana, represented by Advocate Vijay Kumar Gupta, challenged the decision of the Central Processing Centre (CPC), Bengaluru, which was upheld by the National Faceless Appeal Centre (NFAC). The primary contention was the timing of EPF and ESI contributions which Rana claimed were made before the statutory deadline for filing income tax returns.
The tribunal’s deliberation focused on whether the contributions made by the appellant were within the prescribed time limits, thereby influencing the tax liabilities. The Senior Departmental Representative supported the initial findings of the CIT(A), emphasizing compliance with the statutory framework.
However, the tribunal, presided over by Shri Kul Bharat, cited the precedent set by the Delhi High Court in the case of PCIT vs Pro Interactive Service (India) Pvt.Ltd. and the seminal case of Commissioner of Income Tax vs AIMIL Limited, to rule in favor of the appellant. The judgment reiterated that the legislative intent was to encourage timely payment, not penalize it where compliance was met.
The decision to overturn the disallowance by the CIT(A) underscored the importance of adhering to the legislative timelines for contributions towards employee welfare funds. It clarified the interpretations of related tax provisions and reinforced the judiciary’s role in ensuring fair application of tax laws.
The outcome not only supported the appellant’s stance but also set a guiding precedent for similar cases, emphasizing the need for clear documentation and adherence to submission deadlines for tax filings and contributions.
Order pronounced in the open court on February 23, 2022.
Randhir Rana vs ADIT, CPC Ward2(2), Haryana: EPF and ESI Delay Dispute for AY 2019-2020
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