open market. These too amounts were brought to tax by the A.O. under section 18 of the Income­tax Act. The assessee Bank claimed that these amounts were deductible under sections 19 and 20. This was on the footing that the department had brought to tax, the aforestated two amounts as interest on securities under section 18. It is in the light of these facts that one has; to read the judgment in Vijaya Bank's case. In the light of the above facts, it was held that outlay on purchase of income bearing asset was in the nature of capital outlay and no part of the capital outlay can be set off as expenditure against income accruing from the asset in question. In our case, the amount which the assessee received has been brought to tax Civil Appeal No.3291­3294 of 2009, etc. Page 18 of 45under the head “business” under section 28. The amount is not brought to tax under section 18 of the Income­tax Act. After bringing the amount to tax under the head “business”, the department taxed the