https://www.taxtmi.com/caselaws?id=7164 The expression "dealing in or holding of investments" under clause (i) of the second Explanation to section 23A of the Income-tax Act, 1922 must be read broadly, but ownership of shares alone is not enough; the activity must amount to a real, substantial, systematic or organised investment business. Shares held only to preserve managing agencies were not treated as investment-business stock. In deciding whether share-dealing was the principal business, the comparison had to be made on a commercial basis, including connected managing-agency income and dividends from shares retained for that purpose, rather than isolating share-dealing income alone. On that approach, the revenue failed to show that share-dealing was the assessee-company's main business. en-us Fri, 07 Jul 1967 00:00:00 +0530 Wed, 11 Feb 2009 18:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7164 The expression "dealing in or holding of investments" under clause (i) of the second Explanation to section 23A of the Income-tax Act, 1922 must be read broadly, but ownership of shares alone is not enough; the activity must amount to a real, substantial, systematic or organised investment business. Shares held only to preserve managing agencies were not treated as investment-business stock. In deciding whether share-dealing was the principal business, the comparison had to be made on a commercial basis, including connected managing-agency income and dividends from shares retained for that purpose, rather than isolating share-dealing income alone. On that approach, the revenue failed to show that share-dealing was the assessee-company's main business. Case-Laws Income Tax Fri, 07 Jul 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7164