and it was only in the Accounting Year 1947 that the fixed deposits, “were realised on maturity with interest”. He was also of the opinion that the length of the period during which this money “was kept locked in this way” showed clearly that “not the exigencies of pressing necessities, but the motives of investment of surplus fund had actuated the deposits”. He therefore held that the fixed deposits with Imperial Bank were held as an investment quite apart from the business of the appellant and the interest from these deposits was not exempt from income tax. He further held that the exemption as to the profit of a cooperative society extended to its sphere of cooperative activities and therefore interest from investments was no part of the appellant's business profits exempt from taxation. Against this order an appeal was taken to the Income Tax Appellate Tribunal and it was there contended that the Bank did not make the deposits as investments, but in order that cash might be