Rajasthan Knowledge Corporation Ltd. Vs ACIT (ITAT Jaipur)
In a significant ruling, the Income Tax Appellate Tribunal (ITAT) Jaipur has set aside the disallowance of Rs. 14,03,538/- paid as bonus by Rajasthan Knowledge Corporation Ltd. The Tribunal’s decision, pronounced today, comes after the assessee-appellant challenged an order from the National Faceless Appeal Centre (NFAC), Delhi, which had confirmed the disallowance. The NFAC’s order, dated January 16, 2025, had upheld the Assessing Officer’s (AO) action, citing the assessee’s failure to meet the mandatory condition of depositing employee contributions to PF and ESI funds within 15 days of the close of every month. The NFAC had also confirmed a smaller disallowance of Rs. 5,172/- related to late employee PF contributions.
The core of the dispute revolved around the disallowance of the bonus amount. Rajasthan Knowledge Corporation Ltd. had filed its Income Tax Return (ITR) for the assessment year 2018-19 on September 28, 2018. Subsequently, the Central Processing Centre (CPC) issued an intimation under Section 143(1) of the Income Tax Act, 1961, making certain additions, including the aforementioned bonus disallowance and the late PF contribution. The assessee’s rectification application under Section 154 was rejected, leading to the appeal before the CIT(A), which was also dismissed.
