https://www.taxtmi.com/caselaws?id=49546 Share dealings are characterised by the totality of circumstances, including frequency, volume, manner of dealing, account treatment, and use of funds. On the facts described, substantial and repeated purchases and sales of shares and securities, together with organised trading features, supported treatment of the activity as a business rather than mere realisation of investment; the resulting profits were assessable as business income. Income-tax proceedings are not governed by strict res judicata, so an earlier year's view did not prevent examination of later years on their own facts. The later assessment could therefore be made afresh on the evidence available. en-us Thu, 15 Dec 1960 00:00:00 +0530 Wed, 16 Jul 2025 16:20:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49546 Share dealings are characterised by the totality of circumstances, including frequency, volume, manner of dealing, account treatment, and use of funds. On the facts described, substantial and repeated purchases and sales of shares and securities, together with organised trading features, supported treatment of the activity as a business rather than mere realisation of investment; the resulting profits were assessable as business income. Income-tax proceedings are not governed by strict res judicata, so an earlier year's view did not prevent examination of later years on their own facts. The later assessment could therefore be made afresh on the evidence available. Case-Laws Income Tax Thu, 15 Dec 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49546