Exclusive income-tax heads govern interest on securities, which cannot be taxed as business income merely because a bank holds them.

Income-tax heads are mutually exclusive, so income specifically falling under one statutory head cannot be recharacterised under another merely because it arises from banking business. Interest on securities held by a bank was therefore treated as chargeable under the specific head for interest on securities, not as business income. The separate claim for set-off under the relevant provision was not finally determined because the record lacked a sufficient factual finding on whether the securities formed part of the same business, and that issue was left for fresh consideration on fuller facts.

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Issues: Whether interest on securities held by a bank is chargeable under the head "interest on securities" and not as business income under the head "profits and gains of business"; and whether the appeal should be remitted for a fuller finding on the claim for set-off under section 24(2).

Analysis: The scheme of the Income-tax Act classified income under distinct heads and provided separate computational rules for each head. The heads of income were treated as mutually exclusive, so an item specifically falling under one head could not be brought under another merely because of the assessee's business character or because the securities formed part of trading assets. Interest on securities was therefore held to fall within its own specific head and not within business income. As regards the set-off claim under section 24(2), the record did not contain a sufficient finding on whether the securities formed part of the same business for that purpose, so the Court did not finally pronounce on that issue.

Conclusion: Interest on securities was held to fall under section 8 and not under section 10. The question of set-off under section 24(2) was left for fresh consideration on fuller facts.

Final Conclusion: The appeal succeeded to the extent that the matter was sent back for a fresh decision on the unresolved factual basis, while the construction of the charging heads was decided against the assessee.

Ratio Decidendi: Where the statute assigns an item of income to a specific and exclusive head, that item must be computed only under that head and cannot be recharacterised under another head because it arises in the course of the assessee's business.

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