The  Assessing officer  did not accept the explanation of the assessee that the Reserve Bank of India guidelines provided that the income on non-performing assets was not to be credited to the profit and loss account but instead to be shown as receivable in the balance-sheet, that it was to be taken as income in the profit and loss account only when the interest was actually received, that according to the Reserve Bank of India norms, the interest on assets not received in 180 days and the interest which was not received for earlier years was taken to overdue interest reserve and only the interest received during the year was credited to the profit and loss account and offered to tax.  CIT (A) affirmed the order of the AO . Tribunal allowed the appeal of the assessee . 0n appeal by the revenue  the Court affirmed the order of the Tribunal .

.( AY.2009-10)