1996 (1) TMI 8 - SUPREME COURT

Proviso to section 81 seeks to convey that even if a co-operative society is engaged only in the business of banking, but part of its activity is not attributable, to engagement in such activity, income derived from that part of activity would become taxable - income derived from the investment in Govt. securities placed with the SBI/RBI cannot be regarded as an essential part of its banking activity inasmuch as the same does not form part of its stock-in-trade or working/circulating capital