of Income­tax, Mysore v. Vijaya Bank)5, reported in 1976 Tax Law Reporter page 524. This judgment has been subsequently upheld by the Supreme Court in 187 I.T.R. page 541. In view of the judgment of the Karnataka High Court, the department took the view that broken period interest payment cannot be allowed as a deduction because it came within the ambit of interest on securities under section 18 of the Income­tax Act. It is the contention of the department that the assessee­Bank received interest on Dated Government Securities from R.B.I. on half­ yearly basis. That, the assessee Bank also traded in such securities. That the assessee Bank bought Dated Government Securities during the intervening period between two due dates. That, on purchase of the dated Government Security, the assessee became the holder of the security and accordingly, the assessee received half­yearly interest on the Civil Appeal No.3291­3294 of 2009, etc. Page 16 of 45due dates from R.B.I. on purchase. Therefore,