What did the High Court hold?

The High Court held that the issue of disallowance of unreconciled inter-bank/inter-branch entries had been settled in favour of the assessee by a previous ITAT order. Since the Revenue had not appealed that prior decision, the current appeal was allowed.

The appellant, State Bank of Patiala, appealed against an ITAT order concerning the disallowance of outstanding balances for over three years in unreconciled inter-bank/inter-branch entries. The bank argued this was customer money, not its own.

What were the issues?

Whether unreconciled inter-bank/inter-branch balances outstanding for more than three years should be disallowed as income. Whether a prior ITAT decision on a similar issue binds the Revenue.

St. Bank of Ptiala, Patiala vs Comm. of Income Tax, Patiala & Anr | Punjab & Haryana High Court 2025

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 201-1

ITA-954-2008 (O&M) Date of Decision: 19.12.2025 STATE BANK OF PATIALA, PATIALA ...Appellant Vs. COMMISSION OF INCOME TAX, PATIALA & ANR. …Respondents

CORAM:- HON'BLE MR. JUSTICE JAGMOHAN BANSAL HON'BLE MR. JUSTICE AMARINDER SINGH GREWAL

Present:- Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Advocate Mr. Sushrut Singla, Advocate and Mr. Iman Singla, Advocate for appellant-State Bank of Patiala

Mr. Saurabh Kapoor, Sr. Standing Counsel (through V.C.) with

Mr. Rana Gurtej Singh, Jr. Standing Counsel and

Ms. Muskaan Gupta, Advocate

for respondent-Income Tax Department

*** JAGMOHAN BANSAL, J. (ORAL)

The appellant through instant appeal under Section 260A of Income Tax Act, 1961 is seeking setting aside of order dated 06.06.2008 passed by Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short ‘Tribunal’) for the Assessment Year 1995-96. 2.

Learned counsel for the parties are ad idem that only one issue is involved namely disallowance of balance outstanding for more than three years in respect of inter-bank/inter-branch unreconciled entries. 3.

Learned Sr. Advocate for the appellant submits that Tribunal vide order dated 28.03.2016 passed in ITA-391-2011 has settled the issue in favour of assessee. The money lying with Bank with respect to unreconciled DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document

ITA-954-2008 (O&M)

-2-

inter-bank/inter-branch entries does not belong to Bank. This is customer’s money and in case of being unclaimed is transferred to Reserve Bank of India. 4.

Learned counsel for the respondent-Revenue expressed his inability to controvert that issue involved herein stands adjudicated in favour of assessee by Tribunal. No appeal against order passed by Tribunal has been filed. 5.

In view of the fact that issue involved herein stands settled by Tribunal in favour of assessee, we deem it appropriate to set aside impugned order. 6.

Appeal is allowed. 7.

Pending application(s), if any, stands disposed of.

(JAGMOHAN BANSAL)

JUDGE

(AMARINDER SINGH GREWAL)

JUDGE December 19, 2025 Deepak DPA

Whether Speaking/reasoned Yes/No

Whether Reportable

Yes/No DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document

ST. BANK OF PTIALA, PATIALA vs. COMM. OF INCOME TAX, PATIALA & ANR.

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