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    <title>2026 (7) TMI 49 - ITAT BANGALORE</title>
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    <description>Delayed employees&#039; contribution to provident fund and ESI, deposited after the welfare-law due dates but before the return-filing due date, was examined in relation to processing under section 143(1)(a) and rectification under section 154. The Tribunal noted that, for assessment years 2019-20 and 2020-21, the legal position was unsettled and the jurisdictional High Court view favoured allowance, while the Finance Act, 2021 amendment to section 36(1)(va) read with section 43B was stated to apply prospectively from assessment year 2021-22. On that basis, the CPC adjustment and its retention in rectification were held unsustainable, and the disallowance was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794163</link>
      <description>Delayed employees&#039; contribution to provident fund and ESI, deposited after the welfare-law due dates but before the return-filing due date, was examined in relation to processing under section 143(1)(a) and rectification under section 154. The Tribunal noted that, for assessment years 2019-20 and 2020-21, the legal position was unsettled and the jurisdictional High Court view favoured allowance, while the Finance Act, 2021 amendment to section 36(1)(va) read with section 43B was stated to apply prospectively from assessment year 2021-22. On that basis, the CPC adjustment and its retention in rectification were held unsustainable, and the disallowance was deleted.</description>
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