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Querist : Anonymous

Querist : Anonymous (Querist)

18 July 2014 Pls suggest the treatement of following issues in tax audit reporting/ Accounting:

(1) Fee paid for delay in filling of TDS Return U/s 234E whether allowable expense? Does require separate reporting of it in 3CD report?

(2) What will be considered as the date of payment for reporting of "ESIC" & "PF" ?
Whether it will be be:

"Date of Challan Presentation to Bank"
OR
"Actual date of its clearance from the Bank"

Pls suggest urgently.

CA Tejas Mistry

CA Tejas Mistry (Expert)

18 July 2014 (1) Fees paid for delay filling of TDS is a kind of penalty you are talking about which is disallowed and need to report in #CD clause 17 (e)

(2) for the ESIC payment date will be considered as Date of challan presented to Bank

Querist : Anonymous

Querist : Anonymous (Querist)

18 July 2014 pls clarify more or some other experts confirmation req. on query no. 1 pls.

Thanks

Aashok Kumar Sharma online

Aashok Kumar Sharma

(Expert)

02 August 2025 Here’s a quick, clear take on your urgent questions:

1. **Fee paid for delay in filing TDS Return under Section 234E**

* This is a **penalty/fee for delay**, **not an allowable business expense**.
* It **should be disallowed** while computing income.
* Yes, it **needs to be reported separately in Tax Audit Report (Form 3CD), Clause 17(e)** — as payments not allowable as business expenditure.

2. **Date of payment for ESIC & PF**

* The **date of payment is the date of challan presentation to the bank**, not the clearance date.
* So, for audit & reporting, take the **date when the challan was submitted/deposited**, even if clearance happens later.

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