RBI valuation rules for banking investments prevail over general tax computation norms; Tribunal need not rule separately on every ground.

Valuation of banking investments for tax purposes can follow Reserve Bank of India guidelines where the Tribunal finds the RBI framework applicable and the supporting conclusions are factual. The court accepted that section 45Q gives overriding effect to Chapter III-B of the RBI Act in relation to this issue, so the Revenue's reliance on the general income-computation rule did not justify interference. It also held that the Tribunal had sufficiently dealt with the grounds of appeal and was not required to pronounce separately on each ground where the order showed adequate consideration. No substantial question of law arose, and the Revenue's challenge failed.

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Issues: (i) Whether the assessee-bank could value investments in accordance with Reserve Bank of India guidelines while computing taxable income. (ii) Whether the Tribunal was required to pronounce separately on each ground of appeal.

Issue (i): The dispute concerned the treatment of valuation of investments by a banking company for income-tax purposes. The assessment was made under section 143(3) and the Revenue relied on section 145 of the Income-tax Act to contend that income had to be computed by the method regularly employed in earlier years. The Tribunal upheld the assessee's position on the basis that banking investments were governed by the RBI framework and that section 45Q gave overriding effect to Chapter III-B of the Reserve Bank of India Act.

Analysis: The findings accepted below were treated as findings of fact. The Court held that the Tribunal had correctly followed its earlier view and that the RBI regime, enacted for a specific purpose, prevailed in relation to the valuation issue. No substantial question of law arose for interference on this aspect.

Conclusion: The issue was decided in favour of the assessee and against the Revenue.

Issue (ii): Whether the Tribunal failed in law by not pronouncing on each ground of appeal separately.

Analysis: The Court recorded that the Tribunal had dealt with the grounds specifically and that the impugned order contained adequate consideration of the matters raised.

Conclusion: The issue was decided in favour of the assessee and against the Revenue.

Final Conclusion: The appeal did not disclose any substantial question of law and the Revenue's challenge failed.

Ratio Decidendi: Where the Tribunal's conclusions rest on findings of fact and the statutory RBI framework overrides the general accounting-rule objection for valuation of banking investments, no substantial question of law arises for interference.

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