VittSphere ONE Calculators Blog CA Prabhakar Kumar · FCA · ICAI 560762
Case lawCBDT Circulars & Instructions › Statutory position — s.43D: interest on a bad or doubtful debt of a bank, financial institution or NBFC is taxed on credit or receipt, not on accrual, and what Rules 6EA and 6EB prescribe
CBDT Circulars & InstructionsCuts both wayss.43DRule 6EARule 6EBs.36(1)(vii)s.36(1)(viia)s.43Bs.80P(4)s.145

Statutory position — s.43D: interest on a bad or doubtful debt of a bank, financial institution or NBFC is taxed on credit or receipt, not on accrual, and what Rules 6EA and 6EB prescribe

My client is a bank and has stopped accruing interest on non-performing accounts under RBI norms, but the Assessing Officer has added the interest on the mercantile basis. Is there a provision that displaces accrual?

My client is a bank and has stopped accruing interest on non-performing accounts under RBI norms, but the Assessing Officer has added the interest on the mercantile basis. Is there a provision that displaces accrual?

Yes. Section 43D opens "Notwithstanding anything to the contrary contained in any other provision of this Act" and provides that, for the institutions it names, income by way of interest in relation to such categories of bad or doubtful debts as may be PRESCRIBED — having regard to the guidelines issued by the Reserve Bank of India — is chargeable to tax in the previous year in which it is credited to the profit and loss account, or in which it is actually received, whichever is earlier. It therefore displaces the accrual basis for that interest and nothing else. The institutions named on the current departmental edition are a public financial institution, a scheduled bank, a co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank, a State financial corporation, a State industrial investment corporation, and "such class of non-banking financial companies as may be notified by the Central Government in the Official Gazette in this behalf". The prescribed categories are in Rule 6EA of the Income-tax Rules, 1962.

Decided by the CBDT Circulars & Instructions (Not applicable — statutory text), reported as Income-tax Act, 1961, s.43D, as printed on the departmental Year 2025 edition (incometaxindia.gov.in/w/section-43d-34) and the Year 2024 (No. 2) edition (/w/section-43d-33); earlier forms from the Year 2023 edition (/w/section-43d-31), the Year 2019 (No. 2) edition (/w/section-43d-28) and the Year 2009 edition (/w/section-43d). Rules 6EA and 6EB as printed at incometaxindia.gov.in/w/rule-6ea and /w/rule-6eb. The co-operative bank limb was inserted by section 18 of the Finance Act, 2017 with effect from 1 April 2018.. It bears on section 43D, section Rule 6EA, section Rule 6EB, section 36(1)(vii), section 36(1)(viia), section 43B, section 80P(4), section 145 of the Income Tax Act 1961, in Deductions & Disallowances, How Tax Law Is Read and Assessment & Scrutiny matters.

Still good law. The current text was read on two departmental editions, Year 2025 and Year 2024 (No. 2), which agree on the whole of clause (a), on the closing words and on Explanation clauses (c) to (h); they differ only in that the Year 2025 edition prints clause (b) and Explanation clauses (a) and (b) as omitted. That difference is dated by the amendment-footnote lists on both editions, which agree that the omission was made by Act No. 15 of 2024 (the Finance (No. 2) Act, 2024) with effect from 1 April 2025. The label 'good law' describes the text as it stands for assessment year 2025-26 onwards; for earlier years the entry sets out which limb applied and from when. I did not check judicial treatment of s.43D beyond Southern Technologies, which the library already holds. A reader arguing a current year should treat the availability of s.43D to an NBFC as conditional on a Central Government notification that I could not find.

Why it matters

This is a real cash-flow relief and it is regularly missed. Three cautions. First, section 43D does not sanction the RBI's income-recognition norms as such: it works only on the categories PRESCRIBED by rule, so the argument has to be run through Rule 6EA and not through the RBI circular. That is the point on which the Supreme Court's decision in Southern Technologies, already in this library, turned the other way for a provision claimed under s.36(1)(vii). Second, the relief is limited to income BY WAY OF INTEREST; it does not defer anything else. Third, the class of assessee has moved twice in recent years and the current position is conditional. The Finance Act, 2017 inserted the co-operative bank limb with effect from 1 April 2018. The departmental Year 2019 (No. 2) and Year 2023 editions then name "a deposit taking non-banking financial company or a systemically important non-deposit taking non-banking financial company". The Year 2024 (No. 2) and Year 2025 editions replace those words with "such class of non-banking financial companies as may be notified by the Central Government in the Official Gazette in this behalf" — so on the current text an NBFC is inside section 43D only if it falls within a class the Central Government has notified, and NO such notification was located on this pass. An NBFC relying on s.43D for a current year must find the notification before it does so. Note also that clause (b) — the public-company/National Housing Bank limb, to which Rule 6EB attaches — is printed as omitted on the Year 2025 edition, so a housing finance public company can no longer take the section on that footing. Two dates decide which text applies. For assessment years 2020-21 to 2023-24 the NBFC limb named a deposit-taking NBFC or a systemically important non-deposit-taking NBFC (Finance (No. 2) Act, 2019, w.e.f. 1 April 2020). From assessment year 2024-25 those words are gone and the limb reaches only such class of NBFCs as the Central Government notifies (Finance Act, 2023, w.e.f. 1 April 2024). From assessment year 2025-26 the public-company / National Housing Bank limb in clause (b) is omitted altogether (Finance (No. 2) Act, 2024, w.e.f. 1 April 2025), so a housing finance company that has been offering interest on receipt under clause (b) must move to accrual from that year unless some other provision saves it — and Rule 6EB, which prescribed the categories for that limb, is left attached to nothing.

Binding on the department, not on the assessee or the courts. An assessee may rely on a circular that is beneficial to them.

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