Well said sir. Owing to the practical difficulties of assessment of omitted wages, the interest and damages thereon, and considering that the employers will have to generate a huge money to pay the contributions on the omitted wages which would certainly include employees'share which cannot be recovered from the employees, the issue needs to be addressed separately. It is true employer should have contributed contributions according to law and in many cases the law enforcement authorities, ie,the PF Enforcement Officers, have not given a proper direction as to what constitutes PF qualifying salary.It was very late that they themselves started understanding the actual meaning of basic wages. Therefore,partially the responsibility falls on EPFO also. Another important thing is that whenever there is any interpretation of law the EPFO use to issue circulars to employers. In this case so far no such direction has come. It is understood that they have decided to make a cut off date for that. So far no communication has come and as such employers are remitting their contribution as usual.
But my advise is that we should not wait for the communication from the EPFO but shall start contributing on actual. To that extent our liability towards interest and damages could be reduced. 12th August 2019 From India, Kannur