In the result, the appeal of the Revenue in ITA No
43C of the Income-tax Act on the scheduled bank.\n11. Learned counsel for the appellants-Revenue placed reliance on the\njudgment in the case of Southern Technologies Ltd. (supra). However, this\njudgment pertains to non-banking financial companies. UCO Bank's case\n(supra) and Mercantile Bank Ltd. (supra) case squarely applies to the facts\nof the present case