Allowing the appeals the Court held that   if investments in securities were made out of common funds and the assessee had available, non-interest-bearing funds larger than the investments in tax-free securities, disallowance under section 14A could not be made. An assessee definitely has the obligation to provide full material disclosures at the time of filing of the return but there is no corresponding legal obligation upon the assessee to maintain separate accounts for different types of funds held by it. There was no statutory provision which obligated the assessee to maintain separate accounts which might justify proportionate disallowance. The disallowance under section 14A of the Act for the investment made by the assessees in bonds and shares using interest-free funds, would be legally impermissible.  Shares and securities held by a bank are stock-in-trade, and all income received on such shares and securities must be considered to be business income. That is why section 14A would not be attracted to such income.  Central Board of Direct Taxes Circular No. 18 of 2015 dated November 2, 2015  (2015)  378 ITR (St.) 39  (AY. 2001-02)  (Editorial Note : PCIT v. State Bank of Patiayala (2017) 393 ITR 476 (P& H) (HC) approved, Maxopp Investment Ltd v. CIT (2018) 402 ITR 640 (SC) discussed.