as stock­ in­trade. The findings of the Tribunal have been upset by the High Court. The impugned judgment proceeds on the footing that the decision in the case of Vijaya Bank Ltd.1 case would still apply. Thus, as far as Civil Appeal Nos. 3291­3294 of 2009 are concerned, as a finding of fact, it was found that the appellant Bank was treating the securities as stock­in­trade. The said view was upset by the High Court only on the ground of the decision of this Court in the case of Vijaya Bank Ltd1. As the securities were held as stock­in­trade, the income thereof was chargeable under Section 28 of the IT Act. Even the assessing officer observed that considering the repeal of Sections 18 to 21, the interest on securities would be charged as per Section 28 as the securities were held in the normal course of his business. The assessing officer Civil Appeal No.3291­3294 of 2009, etc. Page 41 of 45observed that the appellant­Bank, in its books of accounts and annual report, offered taxation