What did the High Court hold?

The High Court noted that the proposed question of law was covered by a previous judgment concerning the same assessee. Therefore, no substantial question of law arose for consideration.

The Revenue filed an appeal against an ITAT order concerning AY 2013-14, seeking to delete an addition on account of disallowance of interest on overdue deposits. The assessee bank had created a provision for interest based on RBI guidelines regarding a change in accounting policy.

What were the issues?

Whether the ITAT erred in deleting the addition on account of disallowance of interest on overdue deposits, considering the assessee's change in accounting policy as per RBI guidelines.

PCIT vs Oriental Bank of Commerce (Now… | Delhi High Court 2023

$~24 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 592/2023

PR. COMMISSIONER OF INCOME TAX -7 ..... Appellant Through: Mr Puneet Rai, Sr Standing Counsel with Mr Ashvini Kumar and Mr Rishabh Nangia, Advs.

versus ORIENTAL BANK OF COMMERCE (NOW MERGED WITH PUNJAB NATIONAL BANK LTD)

..... Respondent

Through: Mr Rajat Navet, Adv.

CORAM:

HON'BLE MR. JUSTICE RAJIV SHAKDHER

HON'BLE MR. JUSTICE GIRISH KATHPALIA

O R D E R %

20.10.2023

[Physical Hearing/Hybrid Hearing (as per request)] CM Appl. 55111/2023[Application moved on behalf of the appellant/revenue seeking condonation of delay of 470 days in re-filing the appeal] 1. This is an application moved on behalf of the appellant/revenue, seeking condonation of delay in re-filing the appeal. 1.1 According to the appellant/revenue, there is a delay of four hundred and seventy (470) days. 2. Mr Rajat Navet, counsel who appears on behalf of the respondent/assessee, says that since the appeal is taken up for final hearing, he does not oppose the prayer made in the application. 3. Accordingly, the delay is condoned. 4. The application is disposed of, in the aforesaid terms. ITA 592/2023 5. This writ petition concerns Assessment Year (AY) 2013-14. ITA 592/2023

½ This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:33:34

Via the instant appeal, the appellant/revenue seeks to assail the order dated 27.08.2021 passed by the Income Tax Appellate Tribunal [in short, “Tribunal”]. 7. A perusal of the appeal shows that the following question of law is proposed for consideration by this court: “A. Whether on the facts and circumstances of the case and in law Hon’ble ITAT as well as CIT(A) erred in deleting the addition on account of disallowance of interest on overdue deposits of Rs.18,00,00,000 by ignoring the fact that the assessee itself mentioned that there is a change in the accounting policy as guided by the RBI and the liability so created was not crystallized but a provision was created on the basis that an amount of saving rate of interest will be paid to the customers as per the RBI guidelines?”

Mr Puneet Rai, learned senior standing counsel, who appears on behalf of the appellant/revenue, does not dispute the fact that the said proposed question of law, amongst others, was the subject matter of a bunch of appeals, concerning the respondent/assessee, and is covered by the judgment dated 13.09.2023, the lead appeal being ITA 521/2023, titled Pr. Commissioner of Income Tax vs. Oriental Bank of Commerce (now merged with Punjab National Bank Ltd). 6. Having regard to the same, according to us, no substantial question of law arises for consideration by this court. The appeal is, accordingly, closed.

RAJIV SHAKDHER, J

GIRISH KATHPALIA, J

OCTOBER 20, 2023/pmc

Click here to check corrigendum, if any ITA 592/2023

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This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 27/03/2026 at 13:33:34

PR. COMMISSIONER OF INCOME TAX -7 vs. ORIENTAL BANK OF COMMERCE (NOW MERGED WITH PUNJAB NATIONAL BANK LTD)

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