There is no much difference in your query,
According to the gratuity act employees eligible for gratuity if she/he completed 240 days of continuous service in 5 years, however if employees reliving with 4.10 or 4.11 years of service companies use to give gratuity to them if they completed 240 days in the last year.
10th February 2016 From India, Chennai
Please check the below two links has the 2 judgements by Madras high court supporting 4 years and 240 days are enough to become eligible for gratuity.
Court ruling on eligibility for gratuity | Business Line
11th February 2016 From India, Chennai