BHAGABATI PRASAD BANERJEE, J. ( 1 ) THE following question of law is referred to this court by the Tribunal under Section 266 (1) of the Income-tax Act, 1961 ("the Act") :"whether, on the facts and in the circumstances of the case, the Tribunal erred in law in maintaining the order of the Commissioner (Appeals) deleting the addition of Rs. 36,25,303, representing interest on sticky advances for the assessment year 1974-75 ?" ( 2 ) THE assessment year involved is 1974-75 for which the relevant accounting period ended on December 31, 1973. The facts of this case appearing in the statement of the case are as follows : ( 3 ) THE assessee is the Allahabad Bank, Calcutta, and the assessment year involved is 1974-75. ( 4 ) THE assessee is a banking company and its normal business consists of making advances and charging interest on such advances. In respect of certain loans, which had become doubtful of recovery, the assessee charged interest. The assessee charged interest to the party's account and it was credited to the suspense account instead of to the profit and loss account. Such interest amounted to Rs. 36,25,303. The Inspecting Assistant Commissioner was of the opinion that the interest had accrued during the year and that it was the income of the year and was liable to assessment. Hence, the said amount was added back to the total income of the assessee. ( 5 ) THE assessee preferred an appeal to the Commissioner (Appeals) who allowed the claim of the assessee following the Board's instructions dated October 6, 1952, and deleted the entire amount of Rs. 36,25,303. ( 6 ) BEING aggrieved, the Revenue came up in appeal before the Tribunal. The Tribunal, following its earlier order dated June 4, 1985, in the assessee's own case in Income-tax Appeals Nos. 853 and 854/ (Cal) of 1980 and 516/ (Cal) of 1980 for the assessment years 1973-74 and 1974-75, maintained the order of the Commissioner (Appeals) on the point. ( 7 ) OUR attention was drawn to the decision of the Supreme Court in State Bank of Travancore v. CIT, wherein the Supreme Court has held :" that the interest on 'sticky' advances had accrued according to the mercantile system of accounting and the appellant had debited the respective parties with the interest. ( 7 ) OUR attention was drawn to the decision of the Supreme Court in State Bank of Travancore v. CIT, wherein the Supreme Court has held :" that the interest on 'sticky' advances had accrued according to the mercantile system of accounting and the appellant had debited the respective parties with the interest. After the close of the accounting year, the appellant, without giving up the interest, which it could have, as a bad debt, did not offer it for taxation but carried it to the 'interest suspense account'. Carrying a certain amount which had accrued as interest without treating it as a bad debt or irrecoverable interest but keeping it in suspense account was repugnant to Section 36 (1) (vii) read with Section 36 (2) of the Income-tax Act, 1961. The concept of real income could not be so read as to defeat the object and the provision of the statutory enactment. Even if in a given circumstance, the amount might be taken to the interest suspense account for accounting purposes, that would not affect its taxability as such. The interest on 'sticky' advances was rightly treated as income which had accrued to the appellant. "the facts of the instant case as well as the facts of the Supreme Court decision in the case referred to above are identical. The learned advocate appearing for the assessee, Mr. Bhattacharjee, contended that most of the circulars including the circular on which reliance was placed by Mr. Bhattacharjee, namely, the circular dated October 9, 1984, were considered by the Supreme Court in the case of State Bank of Travancore. In the case of State Bank of Travancore, the Supreme Court failed to consider the circulars (sic ). In view of the earlier question of the Supreme Court, that question could not be decided by us. In the case of State Bank of Travancore, the Supreme Court clearly pointed out that these circulars in question were executive in character and were in the nature of concessions and, as such, the same could not alter the provisions of the law. The principle of contemporaneous exposition could not be applicable on the basis of the circulars which were issued for the purpose of giving certain concessions. The principle of contemporaneous exposition could not be applicable on the basis of the circulars which were issued for the purpose of giving certain concessions. The Supreme Court, after considering the scope and effect of the said circulars, had laid down the law on the question of taxability of interest on "sticky" loans and advances by the bank and, as such, it is not open to us to take a contrary view, We are not inclined to accept the submissions made by learned counsel on behalf of the assessee. ( 8 ) ACCORDINGLY, the question is answered in the negative and in favour of the Revenue. ( 9 ) THERE will be no order as to costs.