On appeal, the Court held that the argument that the assessee’s business should be treated as a “single, indivisible and integrated activity” in order to expand the scope of a specific deduction was not tenable. Since the statute specifically mandated “interest on loans”, extending this fiscal benefit to “dividends on shares” would defy the legislative intent. The dividend income did not qualify as profits derived from the business of providing long-term finance. (iii) That by the Finance Act, 1995 ((1995) 213 ITR (Stat) 15), Parliament specifically changed the law to narrow the scope of this deduction because financial corporations were claiming benefits on all sorts of diversified income. Consequently, interest earned from bank deposits was, at best, attributable to the business, but certainly not derived from the activity of providing long-term finance. That the deduction under section 36(1)(viii) was predicated on the financial corporation “providing” the finance. In the case of Sugar Development Fund loans, the funds belonged to the Government of India. The assessee bore no risk and utilised no capital of its own. The receipts in question were service charges paid by the Government for the administrative tasks of monitoring and disbursement. The proximate source of this income was the agency agreement with the Government, not the lending activity itself. A fee received for agency services could not be equated with “profits derived from the business of providing long-term finance”, which implied the deployment of the corporation’s own funds and the earning of interest thereon. Consequently, this income stream had been rightly excluded from the deduction (AY. 1999-2000 to 2004-05, 2007-08)