is an act done in “what is truly the carrying on” of the Banking business. This, it appears to their Lordships, is the more appropriate and satisfactory ground for dealing with the question arising in the present case.” (emphasis added) 17. Therefore, the Privy Council and this Court have consistently held that the securities that Banks acquire as a part of the banking business are held as stock­in­trade and not as an investment. OUR CONCLUSIONS 18. Initially, CBDT issued Circular No. 599 of 1991 and observed that the securities held by Banks must be recorded as their stock­in­trade. The circular was withdrawn in view of the decision of this Court in the case of Vijaya Bank Ltd1. In the year 1998, RBI issued a circular dated 21st April 1998, stating that the Bank should not capitalise broken period interest paid to the seller as a part of cost but treat it as an item of expenditure under the profit and loss account. A similar circular was issued on 21st April 2001, stating that the