Calculating Earned Leave: Should Compensatory Off Days Be Included?

Should we add Compensatory Off in calculating EL?

For example: Physical working days = 267. Comp off = 20.

Then EL = physical working days / 20 or EL = (Physical working days + comp off) / 20.

We are not clear on what constitutes COFF. Is it earned while working on notified holidays or extra hours during normal working days? If it is working on holidays, then it can be counted for EL calculation.

Compensatory Time Off (Comp Off)
Compensatory time off (comp off) is granted by the company in lieu of an employee working on their weekly off day or any declared holiday. The calculation can be based on either counting physical working days plus days worked on holidays or using specific comp off days.