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M/S. Ramnarain Sons (Pr.) Ltd vs Commissioner Of Income Tax, Bombay on 5 December, 1960

In the case of Rannarain Sons Pvt. Ltd. v. Commissioner of Income Tax, Bombay 41 I.T.R. 534 S.C. this Court observed that in considering whether a transaction was or was not an adventure in the nature of trade, the problem must be approached in the light of the intention of the assessee having regard to the legal requirements which were associated with the concept of trade or business. The inference on this question raised by the Tribunal on the facts found was of mixed law and fact and was open to challenge before the High Court on a reference. The question whether the assessee's transactions amounted to dealing in shares and properties or to investment, was a mixed question of law and fact, and the legal effect of the facts found by the Tribunal on which the assessee could be treated as a dealer or an investor, was a question of law.
Supreme Court of India Cites 5 - Cited by 53 - J C Shah - Full Document

Janki Ram Bahadur Ram vs Commissioner Of Income Tax, Calcutta on 31 March, 1965

In the case of Janki Ram Bhadur Ram v. Commissioner of Income Tax, Calcutta 57 I.T.R. 21 S.C. this Court observed that the profit motive in entering a transaction was not decisive, for an accretion to capital did not become taxable income merely because an asset was acquired in the expectation that it might be sold at a profit. This Court further observed that if a transaction was related to the business which was normally carried on by the assessee, though not directly part of it, an intention to launch upon an adventure in the nature of trade might readily be inferred.
Supreme Court of India Cites 7 - Cited by 177 - J C Shah - Full Document

G. Venkataswami Naidu And Co. vs Commissioner Of Income-Tax, Madras on 18 April, 1955

How a question of this nature should be viewed has been indicated by this Court as early as 1958 in G. Venkataswami Naidu & Co. v. Commissioner of Income-tax, 35 I.T.R. 594 S.C.. The question there was whether sale of a land to a company could be treated in the facts and circumstances of the case as an adventure in the nature of trade. There, on the facts this 1085 Court upheld the findings of the Appellate Tribunal in affirming that the assessee knew that it would be able to sell the lands to the managed company whenever it thought it profitable to do so; that the assessee had purchased the four plots of land with the sole intention of selling them to the mills at a profit which intention raised a strong presumption in favour of the view taken by the Tribunal. This Court reiterated that the jurisdiction conferred on the High Court under section 66(1) of the Act of 1922 (hereinafter called the 'old Act') i.e. section 256 of the Act of 1961, (hereinafter called the 'new Act') was limited to entertaining references involving questions of law. It was emphasised that if the point raised on reference related to the construction of a document of title or to the interpretation of the relevant provisions of the statute, it is a pure question of law; and in dealing with it, though the High Court might have due regard for the view taken by the Appellate Tribunal, its decision would not be fettered by the Tribunal's view. It was free to adopt such construction of the document or the statute as appeared to it reasonable. Where the point sought to be raised on a reference was a pure question of fact, the finding of fact recorded by the Tribunal must be regarded as conclusive in proceedings under reference. If, however, such a finding of fact was based on an inference drawn from primary evidentiary facts proved in the case, its correctness and validity were open to challenge in reference proceedings, within, however, narrow limits. The assessee or the revenue could contend that the inference had been drawn on considering inadmissible evidence or after excluding admissible and relevant evidence; and if the High Court was satisfied that the inference was the result of improper admission or exclusion of evidence, it would be justified in examining the correctness of the conclusion. It may also be open to the party to challenge a conclusion of fact drawn by the Tribunal on the ground that it was not supported by any legal evidence; or that the impugned conclusion drawn from the relevant facts was not rationally possible; and if such a plea was established, the court might consider whether the conclusion was not preverse and should not, therefore, be set aside. It was to be remembered, however, that it was within those narrow limits that the conclusions of fact recorded by the Tribunal could be challenged in a reference to the High Court. Such conclusions could never be challenged on the ground that these were based 1086 on misappreciation of evidence. A conclusion reached by the Tribunal on the ground that it is a conclusion on a question of mixed law and fact, is no doubt based upon the primary evidentiary facts, but its ultimate form is determined by the application of relevant legal principles. The need to apply the relevant legal principles tends to confer upon the final conclusion its character of a legal conclusion. In dealing with findings on questions of mixed law and fact the High Court however, has to accept the findings of the Tribunal on the primary questions of facts; but it is open to the High Court to examine whether the Tribunal had applied the relevant legal principles correctly or not; and in that sense, the scope of enquiry and the context of the jurisdiction of the High Court in dealing with such points was the same as in dealing with pure points of law, and not beyond that.
Madras High Court Cites 4 - Cited by 400 - Full Document

P. M. Mohammad Meerakhan vs Commissioner Of Income-Tax, Ernakulam on 12 February, 1969

In P.M. Mohammed Meerakhan v. Commissioner of Income- tax, Kerala, 73 ITR 735 S.C. this Court reiterated that it was not 1093 possible to evolve any single legal test or formula which could be applied in determining whether a transaction was an adventure in the nature of trade or not. The answer to the question must necessarily depend in each case on the total impression and effect of all the relevant factors and circumstances proved therein and which determine the character of the transaction.
Supreme Court of India Cites 8 - Cited by 96 - V Ramaswami - Full Document

Raja Bahadur Kamakhya Narain Singh vs Commissioner Of Income-Tax Bihar And ... on 1 September, 1969

In Raja Bahadur Kamakhya Narain Singh v. Commissioner of Income-Tax, Bihar & Orissa, 77 ITR 253 S.C. the question of adventure in the nature of trade was again considered by this Court and it was reiterated that since the expression "adventure in the nature of trade" implied the existence of certain element in the transactions which in law would invest these with the character of trade or business and the question on that account became a mixed question of law and fact, the court could review the Tribunal's findings if it had misdirected itself in law. It was fairly clear that where a person in selling his investment realised an enhanced price, the excess over his purchase price was not profit assessable to tax as income, but it would be so, if what was done was not a mere realisation of the investment but an act done for making profit. The distinction between the two types of transactions is not always easy to make. Whether the transaction is of one kind or the other depends on the question whether the excess is an enhancement of the value by realising a security or a gain in an operation of profit-making. The assessee might invest his capital in shares with the intention to resell these if in future their sale bring in a higher price. Such an investment, though motivated by a possibility of enhanced value, did not necessarily render the investment a transaction in the nature of trade.
Supreme Court of India Cites 4 - Cited by 176 - J M Shelat - Full Document

Dalhousie Investment Trust Company Ltd vs Commissioner Of Income-Tax ... on 22 November, 1967

The question was again considered by this Court in Dalhousie Investment Trust Co. Ltd. v. Commissioner of Income-Tax (Central), Calcutta, 68 ITR 486 S.C. There this Court on the facts came to the conclusion that the assessee dealt with the shares of Moleod and Co. and the allied companies as stock-in-trade, and that these were in fact purchased even initially not as investments but for the purpose of sale at a profit and therefore the transactions amounted to an adventure in the nature of trade, and the profit derived by the appellant from the sale of share was therefore revenue receipt and as much liable to income-tax. It was held that the decision of department in the earlier years that the transactions were in the nature of change of investments was not binding in the proceedings for assessment during the subsequent years.
Supreme Court of India Cites 6 - Cited by 104 - V Bhargava - Full Document
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