https://www.taxtmi.com/caselaws?id=49596 A solitary purchase and assignment of land rights is taxable as an adventure in the nature of trade only if the transaction, viewed as a whole, shows the essential characteristics of trading activity. The decisive enquiry is the total impression from the facts, including the assessee's position, the nature and acquisition of the property, the commercial setting, and whether the Revenue proves a dominant intention at purchase to resell at a profit rather than hold as capital investment. Mere expectation of appreciation, or later profitable realisation, does not by itself turn capital accretion into income. On the stated facts, the transaction was consistent with capital investment, and the profit was not taxable as business income. en-us Mon, 04 May 1959 00:00:00 +0530 Sat, 24 Sep 2016 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49596 A solitary purchase and assignment of land rights is taxable as an adventure in the nature of trade only if the transaction, viewed as a whole, shows the essential characteristics of trading activity. The decisive enquiry is the total impression from the facts, including the assessee's position, the nature and acquisition of the property, the commercial setting, and whether the Revenue proves a dominant intention at purchase to resell at a profit rather than hold as capital investment. Mere expectation of appreciation, or later profitable realisation, does not by itself turn capital accretion into income. On the stated facts, the transaction was consistent with capital investment, and the profit was not taxable as business income. Case-Laws Income Tax Mon, 04 May 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49596