Clarification Required – Section 18 of Wage Definition (50% Deduction Cap)

I seek clarification on certain interpretational of Section 18 of the Code on Wages, 2019:

1. Wage Definition vs 50% Exclusion Rule
   If, as per the definition of “wages” under the Code, excluded components exceed 50% of total remuneration and are therefore added back to meet the 50% threshold —
   then for the purpose of the deduction limit under Section 18 (read with the 50% ceiling under Section 19), should the deduction cap be computed on:

   • the recomputed “wages” (after 50% adjustment), or

   • the originally structured gross salary?

   Practically, does this mean that deductions cannot exceed 25% of gross remuneration in such scenarios?

2. Section 18(4) – “Subject to the provisions of any other law for the time being in force”
   My understanding is that if any other law mandates deductions exceeding the 50% limit, such deductions would prevail.
   Kindly clarify whether this would include statutory deductions such as Income Tax, and whether such deductions are outside the 50% cap.

3. Absence from Duty (Loss of Pay)
   In case of absence from duty where wages are proportionately reduced (LOP), and gross itself decreases for that wage period:

   • Is the 50% deduction ceiling to be computed on the reduced payable wages for that period?