the purposes of the IT Act, securities would continue to be investments and not stock­in­trade. It was submitted that this Court has repeatedly held that the entries in the books of accounts are not relevant for determining the taxability under the provisions of the IT Act. Reliance is placed on the RBI Circular dated 1st July 2009, which provides that broken period interest is not to be capitalised as part of the cost and is required to be debited to the profit and loss account. Civil Appeal No.3291­3294 of 2009, etc. Page 11 of 45j. It is submitted that as required by the Banking Regulation Act, all three categories of securities are treated in the same manner, and there is no distinction between the securities which are HTM and the other two categories of securities. It was submitted that Banks can always shift the securities falling in the category of HTM to the other two categories. k. It was further urged on behalf of the assessee that the plea based on distinguishing the nature