PF Contribution Delay Excused: Doctrine of Impossibility Overrides Rigid Tax Rule

Schott Glass India Private Ltd. Vs DCIT (ITAT Mumbai)

Doctrine of Impossibility Triumphs Over Rigid 36(1)(va) Disallowance- When the System Fails, Taxpayer Shouldn’t Pay – ITAT Deletes PF Disallowance- Checkmate cannot override genuine impossibility due to portal failure

Assessee, engaged in manufacturing specialized glass for pharmaceutical packaging, filed its return declaring income of ₹154.30 crore. CPC issued an intimation u/s 143(1) making a disallowance of ₹25,23,571 under section 36(1)(va) on the ground that the employees’ PF contribution was deposited one

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