JUDGMENT Deepak Verma, J.— Heard Sri M.V. Seshachala, learned Counsel for the appellants and Sri G. Sarangan, senior Counsel along with Miss. Vani, learned Counsel for the respondent. 2. This appeal is at the instance of the Revenue against the order dated August 9, 2002, passed by the Income Tax Appellate Tribunal in Interest-tax Appeals Nos. 16, 17 and 18/Bang/1997, for the assessment years 1993-94,1994-95 and 1995-96. The appellants raise the following substantial question of law: 1. Whether the Tribunal was correct in holding that the income received by the assessee by way of interest on securities does not form chargeable interest for the purpose of the Interest-tax Act? 3. The assessee is a banking company. In respect of the assessment year 1993-94 a return of income as per the provisions of the Interest-tax Act, 1974, (hereinafter shall be referred to in short as "the Act"), was filed. The matter was taken up for scrutiny assessment. The Assessing Officer was pleased to hold that in accordance with Section 28 of the Act exemption was accorded to the banking companies falling under Section 51 of the Banking Regulation Act, 1949, from levy of interest-tax in respect of income earned from interest on securities with effect from 1996-97 only. For the relevant year, exemption was held to be not applicable. The other questions were also considered and consequently the Assessing Officer held that interest on securities is required to be brought to tax as per the provisions of the Act. 4. The assessee feeling aggrieved by the said order, was constrained to prefer an appeal before the Commissioner of Income Tax (Appeals), Bangalore. The Commissioner of Income Tax (Appeals) has also concurred with the views expressed by the Assessing Officer, thus proceeded to dismiss the appeal preferred by the assessee. The assessee feeling dissatisfied with the aforesaid orders passed by two authorities below, preferred further appeal before the Tribunal. The Tribunal looked at the matter from all angles and allowed the appeal of the assessee holding therein that interest on securities could not have been brought to tax as per the provisions of the Act. Hence, this appeal at the instance of the Revenue. 5. The impugned order passed by the Tribunal shows that as many as three appeals for three different assessment years were heard analogously and were disposed of by the consolidated order. Hence, this appeal at the instance of the Revenue. 5. The impugned order passed by the Tribunal shows that as many as three appeals for three different assessment years were heard analogously and were disposed of by the consolidated order. In view of this, three appeals were preferred in the High Court. We have been given to understand that out of the three appeals, two appeals have already been disposed of on earlier occasion. The order passed by the Division Bench of this Court in I.T.A. No. 537 of 2002 decided on November 27, 2007, has been filed before us for our perusal. The Division Bench has placed reliance on a judgment of the Supreme Court in the matter of Commissioner of Income Tax Vs. Corporation Bank, (2007) 295 ITR 193 SC. The Supreme Court has held that there is a basic difference between loans and advances on the one hand and investment/securities on the other hand. This difference is indicated in the Income Tax Act, the Companies Act as well as the Banking Regulation Act. It further went on to hold that interest earned by the banks on dated Government securities is not liable to interest-tax under Section 2(7) read with Section 4 of the Interest-tax Act, 1974. The reasoning assigned by the Supreme Court finds place in paragraph 2 of the said judgment, which is reproduced here-in below (page 194): 2. The short point which arises in this batch of civil appeals is whether interest earned by the assesses-banks on dated Government securities was liable to be assessed under Section 2(7) read with Section 4 of the Interest-tax Act, 1974. In our view, there is a basic difference between loans and advances on the one hand and investments/securities on the other. This difference is indicated in the provisions of the Income Tax Act, the Companies Act as well as the Banking Regulation Act. These aspects have been discussed in detail in two decisions of the Bombay High Court, namely, Discount and Finance House of India Ltd. Vs. S.K. Bhardwaj, Commissioner of Income Tax and Others, (2003) 3 BomCR 283 , as also in another decision of the Bombay High Court reported in Commissioner of Income Tax Vs. United Western Bank Ltd., (2003) 259 ITR 312 Bom It is not in dispute that the Revenue has accepted the aforestated two judgments of the Bombay High Court. S.K. Bhardwaj, Commissioner of Income Tax and Others, (2003) 3 BomCR 283 , as also in another decision of the Bombay High Court reported in Commissioner of Income Tax Vs. United Western Bank Ltd., (2003) 259 ITR 312 Bom It is not in dispute that the Revenue has accepted the aforestated two judgments of the Bombay High Court. We are in agreement with the view expressed by the Bombay High Court. 6. For the aforesaid reasons, we are of the considered opinion that the question of law as formulated in the appeal has to be answered in favour of the assessee and against the Revenue. We accordingly do so and dispose of the appeal.