JUDGMENT

TULZAPURKAR, J. (Minority view) :— These appeals by certificate from the High Court raise the following two interesting questions of law for our determination :

(1) Whether on the facts and in the circumstances of the case the addition of the sums of Rs. 67,170/-, Rs. 47,777/- and Rs. 57,889/-, representing interest on sticky advances, as income for the assessment years 1965-66, 1966-67 and 1967-68 respectively was justified in law?

(2) Whether on the facts and in the circumstances of, the case the exchange difference of Rs. 1,66,128/- arising on, devaluation of the Indian rupee on 6-6-1966 was rightly treated as income for the assessment year 1967-68?

2. The facts giving rise to the first question lie in a narrow compass and are these. The assessee is a subsidiary of the State Bank of India; it maintains accounts on mercantile system making entries on accrual basis; it adopts the calendar year as its previous year and the calendar years 1964, 1965 and 1966 are respectively the relevant previous years for the assessment years 1965-66, 1966-67 and 1967-68 to which the question relates. In the course of its banking business the assessee charged interest on advances considered d