https://www.taxtmi.com/caselaws?id=193273 Payments for an agreement conferring an exclusive right to enter land, excavate gravel, and remove it over an extended period were held to be capital in nature. The agreement did not transfer a legal estate, but it secured the means of obtaining raw material rather than the raw material itself; the gravel remained part of the soil until excavated and was not stock-in-trade in situ. Applying the circulating capital and fixed capital distinction, the rights acquired were capital assets, so the cost was not deductible as revenue expenditure in computing taxable profits. en-us Mon, 15 Nov 1954 00:00:00 +0530 Fri, 21 Jul 2017 15:14:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193273 Payments for an agreement conferring an exclusive right to enter land, excavate gravel, and remove it over an extended period were held to be capital in nature. The agreement did not transfer a legal estate, but it secured the means of obtaining raw material rather than the raw material itself; the gravel remained part of the soil until excavated and was not stock-in-trade in situ. Applying the circulating capital and fixed capital distinction, the rights acquired were capital assets, so the cost was not deductible as revenue expenditure in computing taxable profits. Case-Laws Income Tax Mon, 15 Nov 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193273