In Brief
A Scheduled Bank purchased government securities as stock-in-trade and paid interest for the "broken period" (accrued interest between coupon dates) to sellers. It deducted this interest as revenue expenditure. The Income Tax Commissioner disallowed the deduction, relying on a prior Supreme Court judgment (Vijaya Bank Ltd.). The Appellate Tribunal allowed the deduction, but the High Court reversed it. The Supreme Court held that broken period interest is revenue expenditure, not capital, when securities are held as stock-in-trade. Securities acquired by banks as part of normal banking business are stock-in-trade, not investments. The repealed Sections 18–21 no longer apply. The Vijaya Bank judgment (on investment interest) does not govern cases assessed under the profits/business head after 1989. Appeals allowed; tribunal decision restored.
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