can come under section 28. In the present case, the department has treated income from securities under section 28. Lastly, the facts in the case of UCO Bank reported in 53 I.T.R. page 250, also support our view in the present case. In UCO Bank's case, the assessee Bank claimed a set off under section 24(2) of the Income­tax Act, 1922 (section 71(1) of the present Act) against its income from interest on securities under section 8 of the 1922 Act (similar to section 28 of the present Act). It was held that UCO Bank was not entitled to such a set off as the income from interest on securities came under section 8 of the 1922 Act. Therefore, even in UCO Bank's case, the department had assessed income from interest on securities right from the inception under section 8 of the 1922 Act and, therefore, the set­off was not allowed under, section 24(2) of the Act. Therefore, UCO Bank's case has also no application to the facts of the present case in which the assessee's income from interest