https://www.taxtmi.com/caselaws?id=49662 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. en-us Thu, 23 May 1957 00:00:00 +0530 Mon, 08 Sep 2014 07:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49662 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. Case-Laws Income Tax Thu, 23 May 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49662