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The High Court of Allahabad rejected the application under section 256(2) of the Income-tax Act, 1961 for the assessment year 1980-81. The court held that the assessee, a bank, was liable to pay tax on interest on sticky loans based on the mercantile system of accounting followed by the assessee. The court noted inconsistencies in the conduct of the assessee regarding the treatment of sticky loans and upheld the decision of the Income-tax Appellate Tribunal. The application was rejected, and costs of Rs. 200 were imposed on the assessee.
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