Jt. CIT v. State Bank of Hyderabad (2025) 302 Taxman 417 (SC) Editorial : State Bank of Hyderabad v. JCIT (2024) 169 taxmann.com 416 (Telangana)(HC)

S. 5 : Scope of total income-Accrual of income-High Court held that interest can be said to have accrued only on date on which it was due as per terms and conditions of security-Interest income on securities is to be taxed on due basis and not on accrual basis-Delay of 220 days-SLP dismissed on the ground that reasons assigned for condonation of delay are neither satisfactory nor sufficient. [S. 145, Art. 136.

Assessing Officer held that interest income was liable to be taxed on accrual basis. High Court held that interest can be said to have accrued only on date on which it was due as per terms and conditions of security and, when instrument or agreement stipulates interest to be payable at specified date, interest does not accrue to holder thereof on any date prior thereto and, therefore, interest would accrue or arise only on date specified in instrument and thus, interest income on securities was to be taxed on due basis and not on accrual basis. Department has filed SLP which was delayed  of 220 days.  SLP is rejected  on the ground that  since reasons assigned for seeking condonation of delay were neither satisfactory nor sufficient in law to be condoned.  (AY. 1994-95)

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