THE UNITED COMMERCIAL BANK LTD.,CALCUTTA vs THE COMMISSIONER OF INCOME-TAX,WEST BENGAL

The Supreme Court ruled that under the Indian Income-tax Act, 1922, specifically Sections 6, 8, 10, and 24(2), 'interest on securities' is a distinct head of income and cannot be set off against business losses. The Court held that the classification of income is mutually exclusive, and thus, the appellant bank's claim to set off previous business losses against interest income was rejected. The case was remitted to the High Court for further findings regarding whether the securities were part of the bank's trading assets.