in (a) securities of the nature referred to in Section 8 of the Indian Income Tax Act; or (b) property of the nature referred to in Section 9 of that Act; (2) dividends, or Civil Appeal No.3291­3294 of 2009, etc. Page 31 of 45(3) the ‘other sources’ referred to in Section 12 of the Indian Income Tax Act.” The Appellate Assistant Commissioner, however, repelled the contention of the appellant. He held that the business of the appellant consisted of ‘lending money, and selling agricultural and other products to its constituents’ which could be planned ahead and required no provision for extraordinary claims He remarked that it appeared from the balance sheets that in the Accounting Year 1945 the Bank invested Rs 13,50,000 as fixed deposits, which, in the following year was raised to Rs 15,00,000 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