for investment. Section 20 dealt with the deduction of (i) expenses in realising the interest and (ii) the interest payable on money borrowed for investment in the case of a Banking Civil Appeal No.3291­3294 of 2009, etc. Page 3 of 45company. Section 21 provided that the interest payable outside India was not admissible for deduction. Sections 18 to 21 were repealed by the Finance Act, 1988, effective from 1st April 1989. We are dealing with cases involving the period post the deletion of the four Sections. 6. In Civil Appeal Nos.3291­3294 of 2009, which is the lead case, the appellant­assessee is a Scheduled Bank. The appellant was engaged in the purchase and sale of government securities. The securities were treated as stock­ in­trade in the hands of the appellant. The amount received by the appellant on the sale of the securities was considered for computing its business income. The appellant consistently followed the method of setting off and netting the amount of interest paid by