STATE BANK OF TRAVANCORE v. CIT

110 ITR 336Reported decision1977#1677 most cited

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

Interest on doubtful debts credited to a suspense account by banking companies is taxable, unless the Income Tax Officer is satisfied that recovery is practically improbable. Subsequent circulars clarified that such interest is taxable only upon actual recovery, particularly if there has been no recovery for three consecutive years.

68

judgments rely on this decision, according to BharatTax’s citation analysis of 366,418 Indian tax judgments — from 1999 to 2026.

Also referred to as

State Bank of Travancore v. CIT · section 119 · section 119(2)(a) · doubtful debts · suspense account · banking companies · taxable income · recovery · income tax

Also reported as

24 Taxmann.com 33788 Taxmann 536

Issues it is cited on

Judgments citing STATE BANK OF TRAVANCORE v. CIT

Adyashakti Himghar Private Limited, Kolkata vs. ACIT Circle 7(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1187/KOL/2025[2017-18]Status: DisposedITAT Kolkata07 Oct 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Adyashakti Himghar Pvt. Ltd….……………………….……….……….……Appellant 11 Paul Street, Kol- 700004.. [Pan: Aacca1114C] Vs. Acit, Circle-7(1), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri Devesh Poddar, Advocate, Appeared On Behalf Of The Appellant. Shri Altaf Hossain, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 07, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 20.05.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 143(1)Section 143(2)Section 143(3)Section 250

…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…

Mohammed Gyasuddin, Kolkata vs. ITO, Ward 30(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1053/KOL/2025[2017-2018]Status: DisposedITAT Kolkata25 Jul 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyi.T.A. No. 1053/Kol/2025 Assessment Year: 2017-2018 Mohammed Gyasuddin,…………………………Appellant 3, Dent Mission Road, Kolkata-700023, West Bengal [Pan:Afvpg2465H] -Vs.- Income Tax Officer,……………….……….....Respondent Ward-30(2), Kolkata, Aayakar Bhawan, Dakshin, 2, Gariahat Road, Kolkata-700031 Appearances By: Shri Miraj D. Shah, A.R., Appeared On Behalf Of The Assessee Shri Abhijit Adhikari, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: July 22, 2025 Date Of Pronouncing The Order: July 25, 2025 O R D E R

Section 139(1)Section 143(2)Section 143(3)Section 40A(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…