Income from securities remains separately taxable, and trading treatment cannot convert interest into business income for earned income relief.

Interest on Government securities is separately chargeable as income from securities under Section 8 of the Income-tax Act, 1922, and cannot be reclassified as business income merely because the securities were part of trading operations. Section 12 applies only when the income is not covered by a specific head, so it cannot displace Section 8 in such cases. Because earned income relief under Section 2(6AA) requires personal exertion, interest on securities does not qualify for that relief. The operative effect is that the interest had to be assessed under Section 8, with no earned income relief available.

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Issues: Whether interest on Government securities received by the assessee, though the securities formed part of its trading operations, could be treated as business income under Section 10 or as income from other sources under Section 12, instead of income from securities under Section 8, so as to qualify for earned income relief.

Analysis: The scheme of the Income-tax Act, 1922 treats income-tax as one tax on aggregate total income, but classifies income under distinct heads for computation and charge. Where income squarely falls within a specific head, it cannot be reassigned to another head merely because the assessee's broader business activity also involves the same assets. Interest on securities is separately chargeable under Section 8 and does not involve personal exertion, which is necessary for earned income relief within Section 2(6AA). The fact that the securities may have been part of trading assets and that dealings in them may yield business profits does not convert the interest itself into business income. Section 12 applies only when the earlier specific heads do not cover the income.

Conclusion: The interest on securities had to be assessed under Section 8 as income from securities and could not be treated as business income or income from other sources. The assessee was not entitled to earned income relief in respect of that interest.

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