https://www.taxtmi.com/caselaws?id=37183 For section 23A of the Income-tax Act, 1922 to apply, the revenue had to prove that the company's real, substantial and primary business was the dealing in or holding of investments. Mere ownership of securities, land, buildings or other assets was not enough to characterise it as an investment company. On the materials discussed, there was no evidence that the assessee-company's principal business was investment activity, so it was not treated as a company whose business consisted wholly or mainly in the dealing in or holding of investments. en-us Fri, 10 Feb 1978 00:00:00 +0530 Sat, 27 Mar 2010 11:44:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37183 For section 23A of the Income-tax Act, 1922 to apply, the revenue had to prove that the company's real, substantial and primary business was the dealing in or holding of investments. Mere ownership of securities, land, buildings or other assets was not enough to characterise it as an investment company. On the materials discussed, there was no evidence that the assessee-company's principal business was investment activity, so it was not treated as a company whose business consisted wholly or mainly in the dealing in or holding of investments. Case-Laws Income Tax Fri, 10 Feb 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37183