Annual Leave Calculation Dilemma: Should Holidays Be Included or Just Working Days?

Hello Everyone, Please let me have clarity on the below scenario. Out of 365 days, our company is only working for 292 days, and the remaining 73 days will be holidays (56 weekly offs, 9 Saturdays, 3 National Holidays, and 9 Festival Holidays). So, for the annual leave calculation, should I consider holidays, or only calculate based on working days only? Thank You.

For eligibility, you can consider the paid days. That means if these holidays or weekly off days are paid days, then you should add these days also for eligibility of 240 days. However, for crediting the leaves, i.e., at the rate of one day for every 20 days worked, you should only consider the days physically present by the employees.

Under any dispensation, all paid holidays, paid weekly offs, approved leave (paid/earned/sick/maternity), or LOP (subject to some conditions) will be taken into account for annual leave calculation. However, absenteeism may not be counted (please check SO).