Land sale not treated as trading venture where purchase was solitary and profit motive alone was insufficient to show business activity.

A solitary purchase of land followed by the later sale of only a small portion was not treated as an adventure in the nature of trade. The assessee was not in the business of dealing in land, and the connected partnership carried on a different line of business. Mere profit motive at the time of purchase, without supporting circumstances showing an intention to trade, was insufficient to characterise the transaction as business activity. The resulting addition was therefore not justified, and the issue was answered in favour of the assessee.

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Issues: Whether the purchase and subsequent sale of land by the assessee constituted an adventure in the nature of trade and gave rise to taxable business profit.

Analysis: The transaction was a solitary purchase followed by sale of only a small portion several years later. The assessee was not engaged in the business of dealing in land, and the associated partnership carried on a different line of business. Mere profit motive at the time of purchase, without other supporting circumstances, was insufficient to infer an intention to embark upon a trading venture.

Conclusion: The transaction did not amount to an adventure in the nature of trade, and the addition was not justified. The question was answered in favour of the assessee.

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