Held that the insertion of Explanation 2 to section 36(1)(va), with effect from 1st April 2021, must mean that so far as the assessment years prior to this assessment year 2021-22 are concerned, the provisions of section 43B cannot be applied for determining the due date under Explanation (now Explanation 1) to section 36(1)(va). (AY. 2019-20)
P.R. Packaging Service v. ACIT (2023) 199 ITD 724 / 221 TTJ 137 / 221 DTR 1 (Mum) (Trib)
S. 36(1)(va) : Any sum received from employees-Employee’s contribution-Belated payment-Entitle to deduction. [S.2(24)(x), 43B, 143(1)(a)]