to be wide, the said decision was mainly based upon the character of the capital gains and not upon their non­ inclusion under the heading “business”. The limited scope of the earlier decision was explained by this Court in CIT v. Chugandas & Co. [(1965) 55 ITR 17, 24] . Therein this Court held that interest from securities formed part of the assessee's business income for the purpose of exemption under Section 25(3). Shah, J., speaking for the Court, observed: “The heads described in Section 6 and further elaborated for the purpose of Civil Appeal No.3291­3294 of 2009, etc. Page 29 of 45computation of income in Sections 7 to 10 and 12, 12­A, 12­AA and 12­B are intended merely to indicate the classes of income : the heads do not exhaustively delimit sources from which income arises. This is made clear in the judgment of this Court in the United Commercial Bank Ltd. case [(1958) SCR 79] , that business income is broken up under different heads only for the purposes of computation of