https://www.taxtmi.com/caselaws?id=9208 Shares held as stock-in-trade, rather than as investment, produced dividend income of a business character, allowing carried-forward business losses to be set off against that income. The determining factor was the character of the shares in the relevant year: the original control objective had ceased, the assessee treated the shares as business assets, later dealings in the same shares were taxed as business income, and borrowings used to acquire them had been allowed as a business deduction. On those facts, the shares were treated as trading stock and the set-off was permitted. en-us Mon, 21 May 1973 00:00:00 +0530 Sat, 20 Jun 2009 14:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9208 Shares held as stock-in-trade, rather than as investment, produced dividend income of a business character, allowing carried-forward business losses to be set off against that income. The determining factor was the character of the shares in the relevant year: the original control objective had ceased, the assessee treated the shares as business assets, later dealings in the same shares were taxed as business income, and borrowings used to acquire them had been allowed as a business deduction. On those facts, the shares were treated as trading stock and the set-off was permitted. Case-Laws Income Tax Mon, 21 May 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9208