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    <title>1954 (11) TMI 3 - Supreme Court</title>
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    <description>Shares acquired solely as part of a single arrangement to secure managing agency rights, and not as stock-in-trade or for share dealing, were treated as a capital investment. When the managing agency objective failed and the shares were later sold, the surplus was held to be a realisation of capital rather than business profit. The receipts were characterised as casual and non-recurring, and therefore not chargeable as revenue income. The operative principle is that where shares are obtained to secure an enduring commercial advantage and not for trading, any later surplus on sale is capital accretion, not taxable business income.</description>
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    <pubDate>Thu, 11 Nov 1954 00:00:00 +0530</pubDate>
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      <title>1954 (11) TMI 3 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=49687</link>
      <description>Shares acquired solely as part of a single arrangement to secure managing agency rights, and not as stock-in-trade or for share dealing, were treated as a capital investment. When the managing agency objective failed and the shares were later sold, the surplus was held to be a realisation of capital rather than business profit. The receipts were characterised as casual and non-recurring, and therefore not chargeable as revenue income. The operative principle is that where shares are obtained to secure an enduring commercial advantage and not for trading, any later surplus on sale is capital accretion, not taxable business income.</description>
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      <pubDate>Thu, 11 Nov 1954 00:00:00 +0530</pubDate>
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