Our Company's administrative office is situated in Kolkata (West Bengal) which has been declared as "RED ZONE" in view of spread of COVID-19. Our Office has been closed ( Under Lock & Key) since 22nd March, 2020. Hence, we could not disburse Salary for March & April 2020 till date. Salary could only be disbursed once Lock Down is relaxed. In view of this reason, we are not in a position to file ECR for wage months March and April 2020.
But, the EPFO / RO of Provident Fund Office has been advising us to file ECR. We have been receiving a number of SMS and mails from RPFO. for filing ECR by 15/05/2020 in order to avail PMGKY benefits.
Now, my question is: Whether we can file ECR without actual payment of Salary for those 2 months?