https://www.taxtmi.com/caselaws?id=465640 The dominant issue was whether employees' PF/ESI contributions paid after the due dates under the respective welfare statutes but before the due date for filing the return under s. 139(1) are deductible under s. 36(1)(va) r/w s. 2(24)(x), and whether Finance Act, 2021 (inserting Explanation 2) applies retrospectively. The ITAT held that, prior to Explanation 2, there was ambiguity on the relevant "due date," and applying the principle against retrospective imposition of hardship as recognised by SC, the amendment was construed as prospective from AY 2021-22. Consequently, for AY 2018-19 the disallowance was deleted and the appeal was allowed. en-us Thu, 12 May 2022 00:00:00 +0530 Sat, 03 Jan 2026 15:56:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465640 The dominant issue was whether employees' PF/ESI contributions paid after the due dates under the respective welfare statutes but before the due date for filing the return under s. 139(1) are deductible under s. 36(1)(va) r/w s. 2(24)(x), and whether Finance Act, 2021 (inserting Explanation 2) applies retrospectively. The ITAT held that, prior to Explanation 2, there was ambiguity on the relevant "due date," and applying the principle against retrospective imposition of hardship as recognised by SC, the amendment was construed as prospective from AY 2021-22. Consequently, for AY 2018-19 the disallowance was deleted and the appeal was allowed. Case-Laws Income Tax Thu, 12 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465640