Provident fund contribution timing under the Income-tax Act was governed by binding precedent, leaving no substantial question of law.

Belated employer provident fund contributions were examined under section 36(1)(va) read with section 2(24)(x) of the Income-tax Act, 1961, in light of the amendment to section 43B. The Karnataka HC noted that an earlier Division Bench had already decided the issue in favour of the assessee and against the Revenue. Applying that binding precedent, the court held that no substantial question of law survived for fresh consideration, and the appeal did not proceed on merits.

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Issues: Whether the belated payment of the employer's contribution to provident fund beyond the stipulated period could be treated as income of the assessee under section 36(1)(va) read with section 2(24)(x) of the Income-tax Act, 1961, in view of the amendment to section 43B of the Act.

Analysis: The issue was already answered by an earlier Division Bench decision of the same High Court in favour of the assessee and against the Revenue. In view of that binding precedent, no substantial question of law survived for fresh consideration in the present appeal.

Conclusion: The question was answered against the Revenue and in favour of the assessee; the appeal was not entertained on merits and stood dismissed.

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