Monday, 20 January 2014

Whether employees' contribution to PF credited after statutory date under respective Provident Fund Acts but within due date of filing return u/s 139 is eligible for deduction u/s 36 - NO: HC

THE issues before the Bench are - Whether employees' contribution to provident fund credited after the statutory date under the respective Provident Fund Acts but within the due date of filing return u/s 139 is eligible for deduction u/s 36 of the Income Tax Act; Whether amendment in section 43B vide Finance Act, 2003 which deleted the second proviso can be applied for interpreting section 36(1)(va); Whether section 36(1)(va) and section 43B operate in two different fields with respect to two different contributions and Whether merely because with
respect to employer's contribution Second Proviso to Section 43B which provided that even with respect to employers' contribution, assessee was required to credit amount in the fund within the due date of the relevant Act, is deleted, it can be said that section 36(1)(va) also stands amended. And the verdict goes against the assessee.
Facts of the case
The assessee is a Corporation run by State of Gujarat, engaged in the business of public transportation. The assessee filed their return of income declaring total loss which was again filed through a revised return declaring more loss on the basis of the final audited accounts and auditor report u/s 44AB after considering the observations / comments of the Statutory Auditor. The case was selected for scrutiny and several notices were issued u/s 142(1) followed by notice u/s 143(2), to which finally the Accounts officer of the assessee along with its Chartered Accountant submitted submissions showing provident fund contribution collected from the employees and deposited with PF Trust as well as Corporation's contribution towards contributory provident fund and its deposit with the PF Trust. Upon verification of the same, it was found that there was shortfall in remittance of provident fund collected from the employees which was required to be treated as income of the assessee as per section 2(24)(x) read with section 36(1) (va) of the Income Tax Act. There was also shortfall in the fund of remittance of assessee Corporation, which according to the AO was required to be disallowed u/s 43B of the Income Tax Act. The AO also added amount as shortfall towards the employers' contributory provident fund and therefore disallowed the same u/s 43B and disallowed the said amount from the expenses claimed by the assessee. On appeal, the CIT(A) directed to partly delete the disallowance as shortfall in employees' contribution to PF Account and partly shortfall in employers' contribution to PF Account by observing that employees' contribution / employer's contribution was deposited before the filing of the return under section 139(1) of the IT Act for the relevant period.
Aggrieved, the Revenue had filed an appeal before the Tribunal, which relied upon the Supreme Court decision in the case of Commissioner of Income-Tax Vs. Alom Extrusions Ltd., confirmed the order of the CIT(A). Still aggrieved, the Revenue has filed this present appeal before the High Court. Several appeals for different AYs were filed. Some of the appeals were filed with respect to disallowance of shortfall of employees' contribution to PF Account u/s 36(1)(va) of the IT Act, some with respect to shortfall in employees' contribution as well as ESI contribution and one of the appeals was related with respect to shortfall in ESI contribution only.
The Departmental Representative vehemently submitted that the Tribunal has materially erred in relying upon the decision of the Supreme Court in the case of Commissioner of Income-Tax Vs. Alom Extrusions Ltd., because in that case, the issue involved was with respect to employer's contribution to PF Account whereas in the present cases, the issue involved was with respect to employees' contribution to PF Account. It was submitted that as such under the Income Tax Act provisions with respect to employees' contribution to PF Account and employers' contribution to PF Account are different i.e. section 43B and section 36(1) (va) of the IT Act are different and distinct and operate in different situation and with respect to different contributions. Therefore, the provision applicable with respect to section 43B cannot be made applicable with respect to section 36(1) (va). The DR also mentioned that any sum received by the assessee from its employee as contribution towards any PF or superannuation fund would be considered as income within Section 2(24) of the Act. The Act. Further, the DR referred to Section 36(1) (va) and submitted that if the employer has not deposited the entire amount towards employees' contribution with the PF Department on or before the relevant date (Due Date) under the PF Act / ESI Act, to the extent there is a shortfall in deposit of the said amount i.e., contribution, the assessee shall not be entitled to the deduction. The DR also argued that while the employees contribution was deposited before the due date of filing return u/s 139 as per section 43B, however, that benefit cannot be extended to employees contribution, and therefore, the deduction u/s 36 cannot be allowed.
The Counsel of the assessee supported the order of the Tribunal and placed great reliance on the decision of Commissioner of Income-Tax Vs. Alom Extrusions Ltd.,. The counsel argued that the Tribunal has rightly deleted the disallowance observing that as the respective assessee have deposited shortfall in employees' contribution in PF Account on or before the due date of filing of the return as provided u/s 139 of the IT Act. For this the Counsel relied on several decisions of the High Courts, wherein the contribution deposited before the due date of filing return was allowed as deduction u/s 36. It was submitted by the Counsel with the deletion with effect from April 1, 2004 by the Finance Act, 2003 of the second proviso to section 43B, which stipulated that contributions to the provident fund and other employee funds should be made within the time mentioned in section 36(1)(va), that is the time allowed under the respective statutes, the position has considerably changed. It was further submitted in view of this amendment, contributions deposited before due date of filing of the return u/s 139 were eligible for deduction. The Counsel relied on another Supreme Court decision in the case of Commissioner of Income-Tax, Gujarat-I Vs. Sarabhai Sons Ltd., and argued that if two views are possible and different High Courts have taken a particular one view, this Court may not take a different view.
In rejoinder, the DR submitted that the controversy in all the decisions cited by the Counsel was with respect to shortfall in employers' contribution and/or whether Amendment in section 43B of the IT Act made by Finance Act, 2003 would have retrospective effect or not.
Having heard the parties, the High Court held that,
+ by the Finance Act 2003, Second Proviso of section 43B of the Act has been deleted and First Proviso to section 43B has also been amended which is reproduced hereinabove. Therefore, with respect to employer's contribution as mentioned in clause (b) of section 43(B), if any sum towards employer's contribution to any provident fund or superannuation fund or gratuity fund or any other fund for the welfare of the employees is actually paid by the assessee on or before the due date applicable in his case for furnishing the return of the income under sub-section (1) of section 139, assessee would be entitled to deduction under section 43B on actual payment and such deduction would be admissible for the accounting year. However, it is required to be noted that as such there is no corresponding amendment in section 36(1) (va). Deletion of Second Proviso to section 43B vide Finance Act 2003 would be with respect to section 43B and with respect to any sum mentioned in section 43(B) (a to f) and in the present case, employer's contribution as mentioned in section 43B(b);
+ therefore, deletion of Second Proviso to section 43B and amendment in first proviso to section 43B by Finance Act, 2003 is required to be confined to section 43B alone and deletion of second proviso to section 43B vide amendment pursuant to the Finance Act, 2003 cannot be made applicable with respect to section 36(1)(va) of the Act. Therefore, any sum with respect to the employees' contribution as mentioned in section 36(1)(va), assessee shall be entitled to the deduction of such sum towards the employee's contribution if the same is deposited in the accounts of the concerned employees and in the concerned fund such as Provident Fund, ESI Contribution Fund, etc. provided the said sum is credited by the assessee to the employees' accounts in the relevant fund or funds on or before the ‘due date' under the Provident Fund Act, ESI Act, Rule, Order or Notification issued thereunder or under any Standing Order, Award, Contract or Service or otherwise. It is required to be noted that as such there is no amendment in section 36(1) (va) and even explanation to section 36(1)(va) is not deleted and is still on the statute and is required to be complied with. Merely because with respect to employer's contribution Second Proviso to section 43B which provided that even with respect to employers' contribution [(section 43(B)b], assessee was required to credit amount in the relevant fund under the PF Act or any other fund for the welfare of the employees on or before the due date under the relevant Act, is deleted, it cannot be said that section 36(1)(va) is also amended and/or explanation to section 36(1)(va) has been deleted and/or amended;
+ Section 2(24)(x) refers to any sum received by the assessee from his employees as contribution and does not refer to employer's contribution. Under the circumstances and so long as and with respect to any sum received by the assessee from any of his employees to which provisions of sub-clause (x) of sub-section 24 of section 2 applies, assessee shall not be entitled to deduction of such sum in computing the income referred to in section 28 unless and until such sum is credited by the assessee to the employees' account in the relevant fund or funds on or before the due date as mentioned in explanation to section 36(1)(va). Therefore, with respect to the employees contribution received by the assessee if the assessee has not credited the said sum to the employees' account in the relevant fund or funds on or before the due date mentioned in explanation to section 36(1) (va), the assessee shall not be entitled to deductions of such amount in computing the income referred to in section 28 of the Act;
+ on considering the controversy before the Supreme Court in the case of Alom Extrusions Ltd. , the said decision would not be applicable to the facts of the present case. In the said case before Alom Extrusions Ltd., the controversy was whether the amendment in section 43B of the Act, vide Finance Act, 2003 would operate retrospectively w.e.f. 1/4/1988 or not. It is also required to be noted that in the case before the Supreme Court, the controversy was with respect to employers' contribution as per section 43(B)(b) of the Act and not with respect to employees' contribution under section 36(1)(va);
+ we are of the opinion that in the present case, and as discussed hereinabove, only one view is possible as canvassed on behalf of the revenue and as observed by under section hereinabove and we are not in agreement with the view taken by the Himachal Pradesh High Court; Karnataka High Court; Rajasthan High Court and Punjab and Haryana High Court in the cases refereed to hereinabove, and therefore, the submission made on behalf of the assessee to follow the decisions of the different High Courts refereed to hereinabove and/or not to take a contrary view cannot be accepted;

+ in view of the above and for the reasons stated above, and considering section 36(1)(va) of the Income Tax Act, 1961 read with sub-clause (x) of clause 24 of section 2, it is held that with respect to the sum received by the assessee from any of his employees to which provisions of sub-clause (x) of clause (24) of section (2) applies, the assessee shall be entitled to deduction in computing the income referred to in section 28 with respect to such sum credited by the assessee to the employees' account in the relevant fund or funds on or before the “due date” mentioned in explanation to section 36(1)(va). Consequently, it is held that the tribunal has erred in deleting respective disallowances being employees' contribution to PF Account / ESI Account made by the AO as, as such, such sums were not credited by the respective assessee to the employees' accounts in the relevant fund or funds (in the present case Provident Fund and/or ESI Fund on or before the due date as per the explanation to section 36(1)(va) of the Act i.e. date by which the concerned assessee was required as an employer to credit employees' contribution to the employees' account in the Provident Fund under the Provident Fund Act and/or in the ESI Fund under the ESI Act. 

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