taken by the Bombay High Court in the case of American Express International Banking Corporation2. Civil Appeal No.3291­3294 of 2009, etc. Page 22 of 45WHETHER SECURITIES ARE HELD AS STOCK­IN­TRADE 14. In the case of Cocanada Radhaswami Bank Ltd.4, the Bank had shown interest on securities held by it as a source of income. The Bank claimed loss against other banking activities and set off the interest on securities against the higher amount shown as loss in other banking activities. The department allowed the loss to be set off against the income under the head “business” and disallowed it under the income under the head “interest on securities”. The Appellate Tribunal confirmed the view. This Court, in paragraphs nos. 3 to 7, held thus: “3. Learned counsel for the Revenue argued that the income from business and securities fell under different heads, namely, Section 10 and Section 8 of the Act respectively, that they were mutually exclusive and, therefore, the losses under the head