Joint development agreement taxability requires factual scrutiny of revenue accrual, possession, refundable deposits, and stock-in-trade character.

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....Taxability under a Joint Development Agreement is examined where land is held as stock-in-trade, with focus on whether revenue accrues, whether an interest-free refundable security deposit constitutes consideration, and whether possession was transferred. The notes state that the capital-gains provision for specified development agreements involving capital assets does not apply to stock-in-trade. They also identify material factual questions requiring examination, including the termination notice and its effect, project status, the deposit's character and use, and the agreement's revenue-recognition terms. The matter described was remitted for fresh consideration after a remand report, objections, and reasonable opportunity, without a merits determination of taxability.....