Banking business. The decision of this Court in United Commercial Bank Ltd. v. CIT [(1958) SCR 79] does not lay down any different proposition. It held, after an exhaustive review of the authorities, that under the scheme of the Income Tax Act, 1922, the head of income, profits and gains enumerated in the different clauses of Section 6 were mutually exclusive, Civil Appeal No.3291­3294 of 2009, etc. Page 27 of 45each specific head covering items of income arising from a particular source. On that reasoning this Court held that even though the securities were part of the trading assets of the company doing business, the income therefrom had to be assessed under Section 8 of the Act. This decision does not say that the income from securities is not income from the business. Nor does the decision of this Court in East India Housing and Land Development Trust Ltd. v. CIT [(1961) 42 ITR 49] support the contention of the Revenue. There, a company, which was incorporated with the objects of