under the head of ‘other sources’. *** (2) The profits of a cooperative society indicates the profit derived from the business which can be truly called the business of the cooperative society. Investments by the society either in securities or in shares or in Bank fixed deposits are made out of surplus funds. The interest or dividend derived from such investment cannot be regarded as part of the profits of the business (sic) qua such Bank and therefore, it is not exempt from income tax (vide Hoshiarpur Central Cooperative Bank v. CIT [24 ITR 346, 3501], 24 I.T.R. 346, 350).” Against this order a case was stated at the instance of the appellant under Section 66(1) of the Act, and the following two questions of law were referred for the opinion of the High Court: (1) Whether, in the facts and circumstances of this case, the receipt of interest on fixed deposits was an income under the head of “other sources”: and Civil Appeal No.3291­3294 of 2009, etc. Page 33 of 45(2) Whether in the