as investment in the books of accounts of Banks, the same should be treated as investment and not stock­in­trade. Another submission of ASG is that Circular No. 18 of 2015 applies only to non­SLR securities. Another submission of learned ASG is that the decision of Vijaya Civil Appeal No.3291­3294 of 2009, etc. Page 12 of 45Bank Ltd.1 would squarely apply as while omitting Sections 18 to 21, corresponding amendments have been made in Sections 28, 56(2)(d) and 57(3) of the IT Act, and the securities are now taxable under the head of “Income from other Sources”. Therefore, the principles laid down in the case of Vijaya Bank Ltd.1 will squarely apply. He argued that the increase in capital by the acquisition of securities results in the expansion of the Bank's capital base, which helps in profit making. Therefore, the expenditure in the nature of broken period interest was capital expenditure. Learned ASG, thus, submitted that the assessees in these cases will not be entitled to a