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 Civil Appeal No.3291­3294 of 2009, etc. Page 20 of 45on securities is assessed under section 28 right from inception, in fact, in UCO Bank's case, the matter was remitted back as it was contended on behalf of UCO Bank that the securities in question were a part of trading assets held by the assessee in the course of its business and the income by way of interest on such securities was assessable under section 10 of the Income­tax Act, 1922 (similar to section 28 of the present Act). It is for this reason that in the subsequent judgment of the Supreme Court in the case of Radhaswami Bank Limited (supra), that the Supreme Court has observed, after reading UCO Bank's case, that where securities were part of trading assets, income by way of interest on such securities could come under section 10 of the