INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
Laliat Kumar, J, Manoj Kumar Aggarwal, AM
Trident Limited – Appellant
Versus
The DCIT – Respondent
| Table of Content |
|---|
| 1. nature of appeal regarding tax disallowance. (Para 1 , 2 , 3) |
| 2. timing and evidence relating to employee contribution. (Para 4 , 5) |
| 3. court's stance on technical compliance. (Para 6 , 7 , 8 , 9 , 10) |
| 4. need for verifiable evidence. (Para 11) |
| 5. restoration of the case for re-evaluation. (Para 12 , 13 , 14) |
This is an appeal filed by the Assessee against the order of the Ld. CIT, Appeal Addl/JCIT(A)-5, Delhi dt. 11/09/2024 for the Assessment Year 2022-23.
2. The assessee has raised sole ground that order passed u/s 250 of the Income Tax Act, 1961 by the Ld. Additional Commissioner of Income Tax (Appeals)-5, Delhi is against law and facts on the file in as much she was not justified to uphold the action of Centralized Processing Centre, Bengaluru in disallowing a sum of Rs. 2,54,70,677/- u/s 36(1)(va) towards employees contribution to provided fund which was delayed by one day due to technical glitch or technical error.
3. It was the case of the assessee that on the due date, i.e., 15th June, 2021, the portal of the Employees’ Provident Fund Organization (EPFO) was not operational and even prior to that, the assessee had made several efforts to coordinate with the Re
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