In the Memorandum of Association of the assessee bank, the objects of the company are stated to be: " (a) To carry on all kinds of banking business, that are generally carried on by Joint Stock Banks. " " (b) To carry on the business of banking in all its branches and departments, including borrowing, raising or taking up money, the lending or advancing money, securities or properties ; the acquiring, holding, issuing and dealing with investment of all kinds; the managing of properties " (c) To purchase, take on lease or in exchange or otherwise acquire any moveable or immoveable property which the Company may think necessary or convenient for the purpose of its business, and to construct, maintain and alter any buildings or works necessary or convenient for the purpose of the company." Apparently, the bank constructed the six storeyed building not only for its own use and occupation, but also, according to the finding of the Appellate Tribunal, for the major part, for the purpose of realising rent from tenants.