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    <title>2026 (1) TMI 758 - MADRAS HIGH COURT</title>
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    <description>Discusses correct head of income for profit on sale of land focusing on distinction between capital asset and trading asset; applies accounting classification, longstanding manner of holding, absence of development, and conduct over years as determinative, with consequence that gains were taxable as capital gains. Notes prior accepted treatment in earlier assessments and reliance on valuation by Valuation Officer for fair market value, reinforcing classification. Observes that post-amalgamation parcels classified as investments formed a separate block distinct from fixed freehold land, and that routine trading activity was not established, with the effect that the impugned reassessment of income as business profit was rejected.</description>
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