https://www.taxtmi.com/caselaws?id=756979 ITAT Delhi allowed assessee's appeal against CPC's rectification order u/s 154 disallowing PF/ESI contributions. The tribunal held the rectification order was void ab initio as CPC failed to issue prior notice and provide opportunity of being heard as mandated under section 154(3). Additionally, the disallowance could not be considered a mistake apparent on record since divergent judicial views existed on the issue, with the jurisdictional Delhi HC in AIMIL Ltd. favoring the assessee's position that PF/ESI contributions paid before due date u/s 139(1) are allowable deductions. en-us Fri, 09 Aug 2024 00:00:00 +0530 Mon, 12 Aug 2024 11:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756979 ITAT Delhi allowed assessee's appeal against CPC's rectification order u/s 154 disallowing PF/ESI contributions. The tribunal held the rectification order was void ab initio as CPC failed to issue prior notice and provide opportunity of being heard as mandated under section 154(3). Additionally, the disallowance could not be considered a mistake apparent on record since divergent judicial views existed on the issue, with the jurisdictional Delhi HC in AIMIL Ltd. favoring the assessee's position that PF/ESI contributions paid before due date u/s 139(1) are allowable deductions. Case-Laws Income Tax Fri, 09 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756979