Documentary bank records proving timely statutory payment remove disallowance and reverse related interest additions.

Documentary bank records that reconcile payment dates can rectify a typographical error in statutory payment entries, and where such records establish payment within the prescribed due date the legal basis for disallowance is removed; accordingly, an addition founded solely on an incorrect date entry is liable to be deleted. The same documentary correction negates any addition for interest on alleged late TDS payment when the timing of payment is shown to be timely, producing deletion of the contested additions and an outcome favourable to the taxpayer.

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Issues: (i) Whether the addition/disallowance of employees' contribution to Provident Fund of Rs. 5,43,881/- sustained where payment date was misstated (typographical error) but bank records show payment within the statutory due date; (ii) Whether the addition on account of interest on late payment of TDS of Rs. 11,907/- is sustainable.

Issue (i): Disallowance of employees' contribution to Provident Fund of Rs. 5,43,881/- on account of a typographical error in the payment date.

Analysis: The Tribunal examined the bank records and reconciled the payment dates showing that the actual payment was made within the due date prescribed under the relevant statute. The disallowance arose solely due to an incorrect date entry; documentary evidence established timely payment, removing the factual basis for disallowance under the assessment order upheld by the Ld. CIT(A).

Conclusion: The disallowance of Rs. 5,43,881/- is not justified and is deleted; decision in favour of the assessee.

Issue (ii): Addition of interest on late payment of TDS of Rs. 11,907/-.

Analysis: The Tribunal considered the assessment adjustments together with the reconciled payment evidence and found that the factual correction on payment timing negated the basis for the addition. The order does not sustain the interest addition when the underpinning payment timing is established as timely.

Conclusion: The addition of Rs. 11,907/- as interest on late payment of TDS is not sustained; decision in favour of the assessee.

Final Conclusion: The appeal is allowed on the merits as the assessee proved timely payment by documentary evidence, resulting in deletion of the impugned additions and overall disposal in favour of the assessee.

Ratio Decidendi: Where documentary bank records satisfactorily establish that statutory payments were made within the prescribed due date, a disallowance founded solely on an incorrect date entry is liable to be deleted.

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