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    <title>1967 (11) TMI 7 - Supreme Court</title>
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    <description>Shares held and dealt with as part of a trading activity were treated as trading stock, so the surplus on their sale was business income rather than capital accretion. The assessee showed no clear conversion of the Elphinstone Mills shares into investment, and the surrounding purchase, sale, and accumulation pattern supported their continued trading character. The receipt on sale was also held to be wholly the price of the shares, because the assessee had no independent right or power to procure resignations, appointments, or a change in management. No separate non-share consideration was identified in the transaction.</description>
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      <title>1967 (11) TMI 7 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5082</link>
      <description>Shares held and dealt with as part of a trading activity were treated as trading stock, so the surplus on their sale was business income rather than capital accretion. The assessee showed no clear conversion of the Elphinstone Mills shares into investment, and the surrounding purchase, sale, and accumulation pattern supported their continued trading character. The receipt on sale was also held to be wholly the price of the shares, because the assessee had no independent right or power to procure resignations, appointments, or a change in management. No separate non-share consideration was identified in the transaction.</description>
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