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Microlesson · 5-min read

Section 36 - Employee Welfare Payments [Bonus, PF, NPS, Gratuity]

# Section 36: Employee Welfare Payments

Four sub-clauses cover the most common employee-side expenses, each with its own discipline.

## (1) Section 36(1)(ii) — Bonus or Commission to Employees

Bonus or commission paid to employees is allowed, subject to two conditions:

1. It must not otherwise be payable as profit or dividend (i.e., disguised distributions to shareholder-employees are disallowed).

2. Section 43B applies — i.e., allowed only if actually paid on or before the due date of filing return u/s 139(1).

## (2) Section 36(1)(iva) — Employer's Contribution to NPS u/s 80CCD

Employer's contribution to the National Pension Scheme is allowed up to the lower of:

LimbDetail
(i) Actual contribution madexxx
(ii) 14% of Salary [Basic + DA (forming part of retirement benefits)]xxx

Any excess contribution is disallowed under Sec 40A(9).

## (3) Section 36(1)(iv) / 36(1)(v) — Employer's Contribution to Funds

Deduction is allowed for employer's contribution to:

  • Statutory Provident Fund (SPF)
  • Recognised Provident Fund (RPF)
  • Approved Gratuity Fund (AGF)
  • Any Approved Provident Fund

Section 43B applies — deduction only if actually paid by the due date of return.

Important: Contribution to unrecognised or unapproved funds is NOT allowed.

## (4) Section 36(1)(va) — Employees' Contribution to Welfare Funds

When the employee's share of PF/ESI etc. is recovered by the employer from the employee's salary, it is first taxed as the employer's income (Sec 2(24)(x)) and then allowed as deduction only if deposited by the due date prescribed under the relevant fund's Act (e.g., PF Act: 15th of next month) — NOT the due date of filing the income-tax return.

This is the critical distinction from employer's contribution: Section 43B does NOT apply here; the fund's own due date is the cut-off. If missed, the disallowance is permanent.

Worked example

### Example 1

Example 1 — Bonus: Company declares bonus of Rs. 10,00,000 in PY 2025-26. Of this, Rs. 8,00,000 is paid before 31.10.2026 (return due date). Rs. 2,00,000 paid in March 2027.

Allowed in PY 2025-26 = Rs. 8,00,000. Disallowed Rs. 2,00,000 (allowed in PY 2026-27 when paid).

### Example 2

Example 2 — NPS contribution: Salary (Basic + DA) of an employee = Rs. 10,00,000. Employer contributes Rs. 1,80,000 to NPS.

  • Limit (i) Actual = Rs. 1,80,000
  • Limit (ii) 14% × 10,00,000 = Rs. 1,40,000

Allowed = Rs. 1,40,000. Excess Rs. 40,000 disallowed u/s 40A(9).

### Example 3

Example 3 — PF contribution: PF for March 2026 (Rs. 50,000). Employee's share Rs. 25,000 was deducted from salary. Employer's share Rs. 25,000.

If deposited on 16th April 2026 (i.e., 1 day after PF Act's 15th due date):

  • Employer's share (Sec 36(1)(iv)) — still allowed if paid by income-tax return due date (Sec 43B applies).
  • Employee's share (Sec 36(1)(va)) — DISALLOWED PERMANENTLY since PF Act deadline (15th April) was missed.

⚠️ Common exam mistakes

  • Treating employees' PF/ESI contribution like employer's contribution — failing to deposit by PF Act's due date (15th of next month) leads to permanent disallowance, regardless of when income-tax return is filed.
  • Claiming bonus paid to a director-shareholder that is essentially a dividend in disguise.
  • Calculating 14% NPS limit on gross salary instead of Basic + DA (forming part of retirement benefits).
  • Claiming employer's contribution to an unrecognised PF or unapproved gratuity fund.
  • Forgetting Sec 43B for bonus — claiming on accrual without paying by ITR due date.
  • Confusing the due dates: employer's share → ITR due date; employee's share → PF Act due date.
  • Applying 10% (old NPS limit) instead of 14% for employer's NPS contribution.
Bare-Act text Section 36(1)(ii), 36(1)(iv), 36(1)(iva), 36(1)(v), 36(1)(va) · Income-tax Act, 1961 · click to expand
Section 36(1)(ii): Any sum paid to an employee as bonus or commission for services rendered, where such sum would not have been payable to him as profits or dividend if it had not been paid as bonus or commission. Section 36(1)(iva): Any sum paid by the assessee as an employer by way of contribution towards a pension scheme, as referred to in section 80CCD, on account of an employee to the extent it does not exceed 14% of the salary of the employee in the previous year. Section 36(1)(va): Any sum received by the assessee from any of his employees to which the provisions of sub-clause (x) of clause (24) of section 2 apply, if such sum is credited by the assessee to the employee's account in the relevant fund or funds on or before the due date.
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