became the holder of the security and accordingly, the assessee received half­yearly interest on the Civil Appeal No.3291­3294 of 2009, etc. Page 16 of 45due dates from R.B.I. on purchase. Therefore, according to the department, the income which the assessee­Bank received came under section 18 of the Income­tax Act interest on securities. Under the circumstances, it was not open to the assessee Bank to claim deduction for broken period interest payment made to the selling/transferor Bank. That, it was not open to the assessee to claim deduction as revenue expenditure for broken period interest payment as no such deduction was permissible under sections 19 and 20 of the Income­tax Act. That, it was not a sum expended by the assessee for realizing interest under section 19 and, therefore, the assessee was not entitled to claim deduction for broken period interest payment as a revenue expenditure under section 28 of the Income­tax Act. In this connection, the department followed the