The assessee was a non-scheduled bank. The assessee took the stand that tax was payable on interest accrued on loans categorized as non-performing assets (NPA)/sticky loans only on receipt basis because the assessee bank was not certain about recovery of principal amount or interest. However, Assessing Officer held that the same was taxable on accrual basis because the assessee followed mercantile system of accounting. High Court held that the amendment made by the Finance Act, 2017 whereby the scope of section 43D was expanded to cover non-scheduled banks was retrospective in nature. Accordingly, assessee was required to pay tax on interest on the sticky loans/NPAs only on receipt basis.(AY 2012-13,  2013-14)