STATE BANK OF TRAVANCORE v. CIT

110 ITR 336Reported decision1977#1692 most cited

What is STATE BANK OF TRAVANCORE v. CIT authority for?

Interest credited by banking companies to a suspense account for doubtful debts is taxable as income, irrespective of the probability of recovery, which led the CBDT to withdraw an earlier circular granting exemption.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 1999 to 2026.

Also referred to as

STATE BANK OF TRAVANCORE v. CIT · Kerala High Court · interest income · banking companies · doubtful debts · suspense account · taxability of interest · CBDT circulars · Section 119 · Section 119(2)(a)

Also reported as

24 Taxmann.com 33788 Taxmann 536

Issues it is cited on

Judgments citing STATE BANK OF TRAVANCORE v. CIT

ARVIND KUMAR JAISWAL,KOLKATA vs. I.T.O., WARD - 33(1), KOLKATA

In the result, appeal of the assessee is allowed

ITA 2499/KOL/2025[2017-2018]Status: DisposedITAT Kolkata13 Jan 2026AY 2017-2018

Bench: Shri George Mathanआयकर अपील सं/Ita No.2499/Kol/2025 (नििाारण वर्ा / Assessment Year :2017-2018) Arvind Kumar Jaiswal, Vs Ito Ward-33(1), Kolkata 10B, Middleton Row, Kolkata-700071 Pan No. :Acwpj 1463 E (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Jaydeep Chakraborty, Advocate राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 13/01/2026 घोषणा की तारीख/Date Of Pronouncement : 13/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 28.02.2025, Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2022-2023. 2. The Appeal Of The Assessee Is Delayed By 187 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Supported With An Affidavit Stating Therein Sufficient Reasons For Condonation Of Delay. Ld.Sr. Dr Has Also Not Objected To Condone The Delay. Considering The Prayer Of The Assessee In The Application & The Sufficient Reasons For Delay, I Condone The Delay Of 187 Days In Filing The Appeal & The Appeal Of The Assessee Is Admitted For Hearing. 3. It Was Submitted By The Ld. Ar That The Notice Issued U/S.143(2) Of The Act, Dated 29.09.2018, Whcih Is Shown At Page 63 Of The Paper Book Is Not As Per The Format Prescribed By The Cbdt. The Said Notice Reads As Follows:-

For Appellant: Shri Jaydeep Chakraborty, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR
Section 143Section 143(2)

…cluded in the assessee's taxable income, provided the Income-tax Officer is satisfied that recovery is practically improbable. Twenty-six years later, on June 20, 1978, in view of the judgment of the Kerala High Court In STATE BANK OF TRAVANCORE v. CIT [1977] 110 ITR 336, the Board by another circular, withdrew with immediate effect the earlier circular. However, by circular dated October 9, 1984, the Board decided that Interest in respect of doubtful debts credited to suspense account by banking companies would be subjected to tax but Interest charged in an account where there has been no recovery for three cons…

ANKUR DEALCOM P. LIMITED,KOLKATA vs. ITO, WARD 10(2),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2204/KOL/2025[2021-2022]Status: DisposedITAT Kolkata11 Dec 2025AY 2021-2022

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.2204/Kol/2025 (निर्धारण वर्ा / Assessment Year : 2021-2022) Ankur Dealcom P. Limited, Vs Ito Ward-10(2), Kolkata C/O S.N.Ghosh & Associates, Advocates, 2, Garstin Place, 2Nd Floor, Suite No.203, Off Hare Street, Kolkata-700001 Pan No. :Aahca 2447 F (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By Shri Somnath Ghosh, Ar रधजस्व की ओर से /Revenue By : None सुनवाई की तारीख / Date Of Hearing : 11/12/2025 घोषणा की तारीख/Date Of Pronouncement : 11/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 22.07.2025 For The Assessment Year 2021-22. 2. It Was Submitted By The Ld.Ar That The Impugned Assessment Order Would Not Survive, Insofar As In The Order U/S.263 Of The Act Against The Said Assessment Order, The Coordinate Bench Of The Tribunal Has Categorically Held That The Notice U/S.143(2) Of The Act, Dated 20.06.2022 Which Is Culminated In The Assessment Order Dated 23.12.2022, Which Is An Impugned Assessment Order Would Not Survive, Insofar As Notice U/S.143(2) Of The Act Was Not In Conformity With The Cbdt Instruction F.No.225/157/2017/Ita-Ii Dated 23-06-2017. It Was The Submission That As Against The Order U/S.263 Of The Act The Coordinate Bench Of The Tribunal

For Respondent: None
Section 12ESection 143(2)Section 143(3)Section 263

…cluded in the assessee's taxable income, provided the Income-tax Officer is satisfied that recovery is practically improbable. Twenty-six years later, on June 20, 1978, in view of the judgment of the Kerala High Court In STATE BANK OF TRAVANCORE v. CIT [1977] 110 ITR 336, the Board by another circular, withdrew with immediate effect the earlier circular. However, by circular dated October 9, 1984, the Board decided that Interest in respect of doubtful debts credited to suspense account by banking companies would be subjected to tax but Interest charged in an account where there has been no recovery for three cons…

M/S. ASSAM INDUSTRIAL DEVELOPMENT CORPORATION LTD.,,GUWAHATI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3, GUWAHATI

In the result, the appeal of the assessee is allowed

ITA 97/GTY/2020[2017-18]Status: HeardITAT Guwahati20 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Manmohan Dasassessment Year: 2017-18 Assam Industrial Development Corporation Ltd……................……….……Appellant A-4, R G Baruah Road, Ambikagiri Nagar, Guwahati, Assam-781024. [Pan: Aacca4720A] Vs. Acit, Circle-3, Guwahati.………..…………………………...……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate & Amalan Bhadra, Fca, Appeared On Behalf Of The Appellant. Shri Sanjay Jha, Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 18, 2025 Date Of Pronouncing The Order : November 20, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Assessee Against The Order Of The Cit(Appeals)-2, Guwahati (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 27.02.2020 For The Ay 2017-18. 2. At The Outset, During The Course Of Assessment Proceedings, The Assessee Has Raised Legal Issue Challenged The Assessment Framed Based On Notice Issued U/S 143(2) Of The Act Which Is Not In Accordance With Instruction No. F. No. 225/157/2017/Ita-Ii Dated 23- 06-2017, Issued By The Cbdt.

Section 143(2)Section 143(3)

…cluded in the assessee's taxable income, provided the Income-tax Officer is satisfied that recovery is practically improbable. Twenty-six years later, on June 20, 1978, in view of the judgment of the Kerala High Court In STATE BANK OF TRAVANCORE v. CIT [1977] 110 ITR 336, the Board by another circular, withdrew with immediate effect the earlier circular. However, by circular dated October 9, 1984, the Board decided that Interest in respect of doubtful debts credited to suspense account by banking companies would be subjected to tax but Interest charged in an account where there has been no recovery for three cons…

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