State Bank of Patiala, Patiala V. Commission of Income Tax, Patiala & ANR.

ITA/954/2008

AI Insights

The case involves the State Bank of Patiala appealing against an order of the Income Tax Appellate Tribunal concerning the Assessment Year 1995-96. The primary issue was the disallowance of balance outstanding for more than three years related to inter-bank/inter-branch unreconciled entries. The Tribunal had previously settled a similar issue in favor of the assessee in a different case, recognizing that the money associated with these unreconciled entries did not belong to the bank but to the customers, and if unclaimed, was transferred to the Reserve Bank of India. The Revenue did not contest this established position, leading the High Court to set aside the earlier order and allow the appeal.

• Counselvise Citation: [] 140 COUNSELVISE.COM (IT) 823693 (HC-CHANDIGARH)
• Appeal Type: Others
• Pronouncement Date: 19-12-2025
• Assessment Year: misc
• Other Referred Cases: ITA-391-2011
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: SAURABH KAPOOR; RANA GURTEJ SINGH; MUSKAAN GUPTA
• Assessee Lawyers: SANJAY BANSAL; GURDEEP SINGH; SUSHRUT SINGLA; IMAN SINGLA
• Keywords: Disallowance; Income tax appellate tribunal; Unreconciled Entries; Inter-bank; Inter-branch
• Section: 260A

Judgement Text

" IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH **** 201-1 ITA-954-2008 (O&M) Date of Decision: 19.12.2025 STATE BANK OF PATIALA, PATIALA ...Appellant Vs. COMMISSION OF INCOME TAX, PATIALA & ANR. …Respondents CORAM:- HON'BLE MR. JUSTICE JAGMOHAN BANSAL HON'BLE MR. JUSTICE AMARINDER SINGH GREWAL Present:- Mr. Sanjay Bansal, Sr. Advocate with Mr. Gurdeep Singh, Advocate Mr. Sushrut Singla, Advocate and Mr. Iman Singla, Advocate for appellant-State Bank of Patiala Mr. Saurabh Kapoor, Sr. Standing Counsel (through V.C.) with Mr. Rana Gurtej Singh, Jr. Standing Counsel and Ms. Muskaan Gupta, Advocate for respondent-Income Tax Department *** JAGMOHAN BANSAL, J. (ORAL) 1. The appellant through instant appeal under Section 260A of Income Tax Act, 1961 is seeking setting aside of order dated 06.06.2008 passed by Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short ‘Tribunal’) for the Assessment Year 1995-96. 2. Learned counsel for the parties are ad idem that only one issue is involved namely disallowance of balance outstanding for more than three years in respect of inter-bank/inter-branch unreconciled entries. 3. Learned Sr. Advocate for the appellant submits that Tribunal vide order dated 28.03.2016 passed in ITA-391-2011 has settled the issue in favour of assessee. The money lying with Bank with respect to unreconciled Printed from counselvise.com DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document ITA-954-2008 (O&M) -2- inter-bank/inter-branch entries does not belong to Bank. This is customer’s money and in case of being unclaimed is transferred to Reserve Bank of India. 4. Learned counsel for the respondent-Revenue expressed his inability to controvert that issue involved herein stands adjudicated in favour of assessee by Tribunal. No appeal against order passed by Tribunal has been filed. 5. In view of the fact that issue involved herein stands settled by Tribunal in favour of assessee, we deem it appropriate to set aside impugned order. 6. Appeal is allowed. 7. Pending application(s), if any, stands disposed of. (JAGMOHAN BANSAL) JUDGE (AMARINDER SINGH GREWAL) JUDGE December 19, 2025 Deepak DPA Whether Speaking/reasoned Yes/No Whether Reportable Yes/No Printed from counselvise.com DEEPAK BISSYAN 2025.12.22 10:07 I attest to the accuracy and integrity of this document "