PCIT-2 Vs Central Bank of India (Bombay High Court)
The Bombay High Court dismissed the Revenue’s appeal for Assessment Year 2008-09, declining to admit the matter on the ground that no substantial question of law arose. The appeal proposed two questions: first, whether separate provisions for rural and non-rural advances are permissible under Section 36(1)(viia) for the purpose of set-off of bad debts under Section 36(1)(vii); and second, whether interest income on securities accrues on the due date of payment rather than on a day-to-day basis, particularly where broken period interest is claimed as expenditure.
Read SC Judgment in this case: SC Dismisses Revenue SLP Because No Substantial Question of Law Arose on Interest Accrual
On the first issue, the Court noted that the Income Tax Appellate Tribunal (ITAT) had relied on its earlier decisions in the assessee’s own case for several prior assessment years. The Court had adjourned the matter to ascertain whether any appeals were filed against those decisions. As nothing on record indicated that appeals had been filed, the Court held that no substantial question of law arose. It further observed that the Tribunal had also followed the Supreme Court’s decision in Catholic Syrian Bank Ltd. v. Commissioner of Income-tax.
