of the assessee? The Tribunal and the High Court found that they were the assessee's trading assets and the Civil Appeal No.3291­3294 of 2009, etc. Page 25 of 45income therefrom was, therefore, the income of the business. If it was the income of the business, Section 24(2) of the Act was immediately attracted. If the income from the securities was the income from its business, the loss could, in terms of that section, be set off against that income. 6. A comparative study of sub­sections (1) and (2) of Section 24 yields the same result. While in sub­section (1) the expression “head” is used, in sub­section (2) the said expression is conspicuously omitted. This designed distinction brings out the intention of the legislature. The Act provides for the setting off of loss against profits in four ways. To illustrate, take the head “profits and gains of business, profession or vocation”. An assessee may have two businesses. In ascertaining the income in each of the two businesses, he is