Dalhousie Investment Trust Co. Ltd. v. CIT

68 ITR 486Supreme Court of India1968#3312 most cited

What is Dalhousie Investment Trust Co. Ltd. v. CIT authority for?

Transactions involving the purchase and sale of shares constitute trading activity if the interest paid on borrowed funds for such purchases exceeds the return generated from the shares, indicating that the interest payments are commensurate with the share returns.

36

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2010 to 2025.

Also referred to as

Dalhousie Investment Trust Co. Ltd. v CIT · 68 ITR 486 (SC) · trading activity · purchase and sale of shares · interest paid on borrowed funds · return on shares · business income

Sections most often in play

Section 140ASection 143(1)(a)Section 143(3)Section 147Section 148Section 154Section 234BSection 250
Read the full judgment

Judgments citing Dalhousie Investment Trust Co. Ltd. v. CIT

The A.P. State Civil Supplies Corporation Ltd vs. The Deputy Director Of Income-tax (Exemptions)-III

ITTA/429/2011HC Telangana18 Nov 2025

Bench: P.SAM KOSHY,SUDDALA CHALAPATHI RAO

Addl CIT Sp RG 22, Mumbai vs. Dsp Merrill Lynch Ltd, Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 2198/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

…ad been accepted by the Department in earlier years and in part Ay 92-93. The assessee has invested his own money in the shares and it has not borrowed funds to invest in shares. It has been held in the case of Dalhousie Investment Trust Company Limited v Cit 68 ITR 486(SC) that where the interest paid on moneys borrowed for purchases of shares was higher than the return on shares, the transactions of purchase and sale of shares would amount to trading activity. In other words, the interest payments on the amount borrowed would commensurate with the returns earned from the shares. It is also noticed that the issu…

Dsp Merrill Lynch Limited, Mumbai vs. Addl C.I.T. Range 4(1), Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 1581/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

…ad been accepted by the Department in earlier years and in part Ay 92-93. The assessee has invested his own money in the shares and it has not borrowed funds to invest in shares. It has been held in the case of Dalhousie Investment Trust Company Limited v Cit 68 ITR 486(SC) that where the interest paid on moneys borrowed for purchases of shares was higher than the return on shares, the transactions of purchase and sale of shares would amount to trading activity. In other words, the interest payments on the amount borrowed would commensurate with the returns earned from the shares. It is also noticed that the issu…

M/S.Sheetal Real vs. Income Tax Officer

In the result, the appeal fails and the substantial questions of law

ITA/83/2010HC Orissa08 Feb 2022

Bench: DR. JUSTICE S. MURALIDHAR (CJ),MR. JUSTICE R.K.PATTANAIK

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 260ASection 372A

…5. 4. Aggrieved by such order the assessee preferred appeal before the Commissioner of Income Tax (Appeals), XI, Kolkata {CIT(A)}. The assessee 3 221 ITR 18 41964 15 STC 644 5(1968) 68 ITR 486 (SC) ITA/83/2010 REPORTABLE Page 6 of 60 contended that the mention of the business of share trading was one of the main objects in the memo…

Canara Securities Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-2(1), Hyderabad

In the result, appeal of the assessee is partly allowed

ITA 2321/HYD/2018[2010-11]Status: DisposedITAT Hyderabad03 Jul 2019AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmanassessment Year: 2010-11 Canara Securities Ltd., Vs. Dy. Commissioner Of Hydereabad. Income-Tax, Central Circle – 2(1), Pan – Aaacc8283G Hyderabad. Appellant Respondent Assessee By: Shri Ramkishore Jhawar Revenue By: Shri Nilanjan Dey Date Of Hearing: 08/05/2019 Date Of Pronouncement: 03/07/2019 O R D E R

For Appellant: Shri Ramkishore JhawarFor Respondent: Shri Nilanjan Dey
Section 143(1)Section 147Section 148

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCH ‘B', HYDERABAD BEFORE SMT. P. MADHAVI DEVI, JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER Assessment Year: 2010-11 Canara Securities Ltd., vs. Dy. Commissioner of Hydereabad. Income-tax, Central Circle – 2(1), PAN – AAACC8283G Hyderabad. Appellant Respondent Assessee by: Shri Ramkishore Jhawar Revenue by: Shri Nilanjan Dey Date of hearing: 08/05/2019 Date of pronouncement: 03/07/2019 O R D E R PER S. RIFAUR RAHMAN, AM: This appeal filed by the assessee is directed against the order of CIT(A) – 6, Hyderabad, dated, 03/09/2018 for AY 2010-11. 2.…

Telenor (India) Communications Pvt. Ltd., New Delhi vs. ACIT, Circle- 25(1), New Delhi

In the result appeal of assessee is partly allowed for statistical purposes

ITA 7541/DEL/2017[2014-15]Status: DisposedITAT Delhi04 Dec 2018AY 2014-15

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri G.S. Agarwal, Sr. Adv. &nFor Respondent: Shri S.S. Rans, CIT(DR)

…vs. CIT, 51 ITR 829 (Ker.) (iii) CIT vs. P.K.N. Co. Ltd., 80 ITR 65(SC) 40 41 (iv) R. Dalmia vs. CIT, 137 ITR 665 (Del.) (v) Lakshminarayan Ram Gopal & Son Limited vs. Government of Hyderabad, 25 ITR 449 (SC) (vi) Dalhousie Investment Trust Co. Ltd. vs. CIT, 68 ITR 486 (SC). (g) He had objected to the admission of additional evidence furnished, without stating which of the evidence furnished by the assessee, was additional evidence. REJOINDER BY APPELLANT 28. The appellant filed its rejoinder on 03.04.2018 on the contentions raised by the Ld. CIT (DR) in its submissions. Regarding the first contention, the Sen…

ACIT, New Delhi vs. M/S. Shri Finance, New Delhi

The appeal of the department stands dismissed

ITA 6064/DEL/2014[2010-11]Status: DisposedITAT Delhi23 Oct 2018AY 2010-11

Bench: Shri N.K.Saini, Hon’Ble & Shri Sudhanshu Srivastavaassessment Year: 2010-11 Acit Shri Finance Circle-31(1) 4, Scindia House Vs. New Delhi New Delhi Pan : Aacfs9120K Appellant Respondent Revenue By : Shri K. Tiwari, Sr. Dr Assessee By : Shri U.N.Marwah, Ca Date Of Hearing : 25.07.2018 Date Of Pronouncement : 23.10.2018

For Appellant: Shri U.N.Marwah, CAFor Respondent: Shri K. Tiwari, Sr. DR
Section 10(34)Section 10(38)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’ NEW DELHI BEFORE SHRI N.K.SAINI, HON’BLE VICE PRESIDENT AND SHRI SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER Assessment Year: 2010-11 ACIT Shri Finance Circle-31(1) 4, Scindia House Vs. New Delhi New Delhi PAN : AACFS9120K Appellant Respondent Revenue by : Shri K. Tiwari, Sr. DR Assessee by : Shri U.N.Marwah, CA Date of hearing : 25.07.2018 Date of pronouncement : 23.10.2018 O R D E R PER SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER : This appeal has been preferred by the department against order dated 14.08.2014 passed by the Ld. Commissioner of Income Tax (Appeal…

G2 Corporate Services LLP, (Formerly M/S. G2 Corporate Services Ltd), Sec'Bad, Hyderabad vs. DCIT, Circle-2(3), Hyderabad

In the result, both the appeals of assessee are partly allowed

ITA 833/HYD/2016[2009-10]Status: DisposedITAT Hyderabad08 Jun 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri M. Sitaram, DR
Section 143(1)(a)Section 143(3)Section 14A

…from its records as to whether it has maintained any distinction between those shares which are its stock-in-trade and those which are held by way of investment. " (b) The Hon'ble Supreme Court in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1967J 66 ITR 473 (SC) has observed as under: "Mere fact that an investment company periodically varies its investment does not necessarily mean that the profits resulting from such variation are taxable under the Income-tax Act. Variation of its investments must amount to dealing in investments before such profits can be taxed as income under the Income Tax Act. "…

G2 Corporate Services LLP, (Formerly M/S. G2 Corporate Services Ltd), Sec'Bad, Hyderabad vs. DCIT, Circle-2(3), Hyderabad

In the result, both the appeals of assessee are partly allowed

ITA 832/HYD/2016[2009-10]Status: DisposedITAT Hyderabad08 Jun 2018AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri B. Ramakotaiah

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri M. Sitaram, DR
Section 143(1)(a)Section 143(3)Section 14A

…from its records as to whether it has maintained any distinction between those shares which are its stock-in-trade and those which are held by way of investment. " (b) The Hon'ble Supreme Court in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1967J 66 ITR 473 (SC) has observed as under: "Mere fact that an investment company periodically varies its investment does not necessarily mean that the profits resulting from such variation are taxable under the Income-tax Act. Variation of its investments must amount to dealing in investments before such profits can be taxed as income under the Income Tax Act. "…

Anita Kumaran, Chennai vs. ACIT Non Corporate Circle 15(1), Chennai

In the result, the appeal of the assessee is allowed pro-

ITA 3163/CHNY/2017[2013-14]Status: DisposedITAT Chennai03 May 2018AY 2013-14

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

For Respondent: Ms. Vijaya Prabha, IRS, JCIT
Section 14Section 14A

…and the activity had all attributes of an adventure in the nature of business. Reliance was placed on the judgment of Hon’ble Apex Court in the case of CIT vs. Sutlej Cotton Mills Supply Agency Ltd, 100 ITR 706, Dalhousie Investment Trust Co. Ltd. vs. CIT, 68 ITR 486 and Sardar Indra Singh & Sons Ltd vs. CIT, 24 ITR 415. Now before us, ld. Authorised Representative strongly 6. assailing the orders of the lower authorities submitted that assessee had invested in the equity shares of various companies about five to six years back. According to him, the only sales effected by her during the relevant previous y…

Ramesh G Porwal, Pune vs. Assistant Commissioner of Income-Tax

In the result, the appeal of the assessee is partly allowed

ITA 1727/PUN/2014[2005-06]Status: DisposedITAT Pune16 Mar 2018AY 2005-06

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri R.G. NaharFor Respondent: Shri Dr. Vivek Aggarwal
Section 143(3)Section 14A

…tures of business income, with reference to a number of decisions by the apex court, as under, has neither been disputed nor is disputable: (a) Raja Bahadur Visheshwara Singh V. CIT (1961) 41 ITR 685(SC); (b) Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (SC); (c) CIT v. Sutlej Cotton Mills Supply Agency Ltd. [1975] 100 ITR 706 (SC); (d) A.V. Thomas & Co. Ltd. v. CIT [1963] 48 ITR 67 (SC); (e) CIT v. P.K.N. Co. Ltd. [1966] 60 ITR 65 (SC); and (f) CIT v. Associated Industrial Development Co. (P.) Ltd.[1971] 82 ITR 586 (SC). 5.2.1.1. The Assessing Officer examined the details of the transactions w…

Raguvalika Trading Pvt Ltd ( Since Merged With M.M.Murarka Share & Securities Pvt Ltd), Kolkata vs. D.C.I.T Cir - 4, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 851/KOL/2013[2008-2009]Status: DisposedITAT Kolkata14 Feb 2018AY 2008-2009

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A Nos. 848 To 850/Kol/2013 Assessment Years : 2005-06 To 2007-08 Ruguvalika Trading Pvt. Ltd. -Vs- Dcit, Circle-4, Kolkata (Since Merged With M.M. Murarka Share & Securities Pvt. Ltd. [Pan: Aabcr 5743 B] (Appellant) (Respondent)

For Appellant: Shri J.P.Khaitan, Sr. CounselFor Respondent: Shri P.K.Srihari, CIT
Section 143(3)

…be served by remanding the matter. We do not find any issue, which has remained unattended. For the aforesaid reasons, we hold that the judgment under challenge is not perverse." 4. The judgment in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (Sc) referred by the Assessing Officer does not assist the revenue because in that on appreciation of facts it was found as follows:— "On the facts, that the appellant dealt with the shares of McLeod and Co. and the allied companies as stock-in-trade, that they were in fact purchased even initially not as investments but for the purpose of sale at…

Raguvalika Trading Pvt Ltd ( Since Merged With M.M.Murarka Share & Securities Pvt Ltd), Kolkata vs. D.C.I.T Cir - 4, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 850/KOL/2013[2007-08]Status: DisposedITAT Kolkata14 Feb 2018AY 2007-08

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A Nos. 848 To 850/Kol/2013 Assessment Years : 2005-06 To 2007-08 Ruguvalika Trading Pvt. Ltd. -Vs- Dcit, Circle-4, Kolkata (Since Merged With M.M. Murarka Share & Securities Pvt. Ltd. [Pan: Aabcr 5743 B] (Appellant) (Respondent)

For Appellant: Shri J.P.Khaitan, Sr. CounselFor Respondent: Shri P.K.Srihari, CIT
Section 143(3)

…be served by remanding the matter. We do not find any issue, which has remained unattended. For the aforesaid reasons, we hold that the judgment under challenge is not perverse." 4. The judgment in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (Sc) referred by the Assessing Officer does not assist the revenue because in that on appreciation of facts it was found as follows:— "On the facts, that the appellant dealt with the shares of McLeod and Co. and the allied companies as stock-in-trade, that they were in fact purchased even initially not as investments but for the purpose of sale at…

Raguvalika Trading Pvt Ltd ( Since Merged With M.M.Murarka Share & Securities Pvt Ltd), Kolkata vs. D.C.I.T Cir - 4, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 849/KOL/2013[2006-07]Status: DisposedITAT Kolkata14 Feb 2018AY 2006-07

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A Nos. 848 To 850/Kol/2013 Assessment Years : 2005-06 To 2007-08 Ruguvalika Trading Pvt. Ltd. -Vs- Dcit, Circle-4, Kolkata (Since Merged With M.M. Murarka Share & Securities Pvt. Ltd. [Pan: Aabcr 5743 B] (Appellant) (Respondent)

For Appellant: Shri J.P.Khaitan, Sr. CounselFor Respondent: Shri P.K.Srihari, CIT
Section 143(3)

…be served by remanding the matter. We do not find any issue, which has remained unattended. For the aforesaid reasons, we hold that the judgment under challenge is not perverse." 4. The judgment in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (Sc) referred by the Assessing Officer does not assist the revenue because in that on appreciation of facts it was found as follows:— "On the facts, that the appellant dealt with the shares of McLeod and Co. and the allied companies as stock-in-trade, that they were in fact purchased even initially not as investments but for the purpose of sale at…

Raguvalika Trading Pvt Ltd ( Since Merged With M.M.Murarka Share & Securities Pvt Ltd), Kolkata vs. D.C.I.T Cir - 4, Kolkata

In the result, the appeal of the assessee in ITA No

ITA 848/KOL/2013[2005-06]Status: DisposedITAT Kolkata14 Feb 2018AY 2005-06

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm] I.T.A Nos. 848 To 850/Kol/2013 Assessment Years : 2005-06 To 2007-08 Ruguvalika Trading Pvt. Ltd. -Vs- Dcit, Circle-4, Kolkata (Since Merged With M.M. Murarka Share & Securities Pvt. Ltd. [Pan: Aabcr 5743 B] (Appellant) (Respondent)

For Appellant: Shri J.P.Khaitan, Sr. CounselFor Respondent: Shri P.K.Srihari, CIT
Section 143(3)

…be served by remanding the matter. We do not find any issue, which has remained unattended. For the aforesaid reasons, we hold that the judgment under challenge is not perverse." 4. The judgment in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (Sc) referred by the Assessing Officer does not assist the revenue because in that on appreciation of facts it was found as follows:— "On the facts, that the appellant dealt with the shares of McLeod and Co. and the allied companies as stock-in-trade, that they were in fact purchased even initially not as investments but for the purpose of sale at…

Principal Commissioner of Income Tax-7 vs. Pavitra Commercial Ltd

The appeals are dismissed

ITA/150/2018HC Delhi09 Feb 2018

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

…Page 1 of 6 ITA 146/2018 & connected appeals $~11, 14 & 15 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 09.02.2018 + ITA 146/2018 & CM APPL. 5059/2018 ITA 149/2018 ITA 150/2018 & CM APPL. 5080/2018 PRINCIPAL COMMISSIONER OF INCOME TAX-7..... Appellant Through Mr. Sanjay Kumar, Adv. versus PAVITRA COMMERCIAL LTD. ..... Respondent Through None. CORAM: HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A. K. CHAWLA HON'BLE MR. JUSTICE S. RAVINDRA BHAT (ORAL) % In these appeals, the questions of law urge…

Principal Commissioner of Income Tax-7 vs. Pavitra Commercial Ltd

The appeals are dismissed

ITA/146/2018HC Delhi09 Feb 2018

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

…Page 1 of 6 ITA 146/2018 & connected appeals $~11, 14 & 15 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 09.02.2018 + ITA 146/2018 & CM APPL. 5059/2018 ITA 149/2018 ITA 150/2018 & CM APPL. 5080/2018 PRINCIPAL COMMISSIONER OF INCOME TAX-7..... Appellant Through Mr. Sanjay Kumar, Adv. versus PAVITRA COMMERCIAL LTD. ..... Respondent Through None. CORAM: HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A. K. CHAWLA HON'BLE MR. JUSTICE S. RAVINDRA BHAT (ORAL) % In these appeals, the questions of law urge…

Principal Commissioner of Income Tax-7 vs. Pavitra Commercial Ltd

The appeals are dismissed

ITA/149/2018HC Delhi09 Feb 2018

Bench: HON'BLE MR. JUSTICE S. RAVINDRA BHAT,HON'BLE MR. JUSTICE A. K. CHAWLA

…Page 1 of 6 ITA 146/2018 & connected appeals $~11, 14 & 15 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 09.02.2018 + ITA 146/2018 & CM APPL. 5059/2018 ITA 149/2018 ITA 150/2018 & CM APPL. 5080/2018 PRINCIPAL COMMISSIONER OF INCOME TAX-7..... Appellant Through Mr. Sanjay Kumar, Adv. versus PAVITRA COMMERCIAL LTD. ..... Respondent Through None. CORAM: HON'BLE MR. JUSTICE S. RAVINDRA BHAT HON'BLE MR. JUSTICE A. K. CHAWLA HON'BLE MR. JUSTICE S. RAVINDRA BHAT (ORAL) % In these appeals, the questions of law urge…

ITO, Ward-36(2), Kolkata vs. M/S. Sri Ram Commercial Co., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2200/KOL/2014[2011-2012]Status: DisposedITAT Kolkata13 Apr 2017AY 2011-2012
Section 142(1)Section 14ASection 40

…IN THE INCOME TAX APPELLATE TRIBUNAL,‘A’ BENCH, KOLKATA Before: Shri M.Balaganesh, Accountant Member and Shri S.S.Viswanethra Ravi, Judicial Member A.Y 2011-12 Income Tax Officer … Appellant Ward 36(2), Kolkata Vs M/s. Sri Ram Commercial Co. … Respondent PAN:AAMFS 4086Q Appearances by: Shri Sallong Yaden, Addl.CIT, ld.Sr.DR for the Shri Kalyan Acharya Bhaduri, Advocate, ld.AR for the assessee Date of hearing : 30-01-2017 Date of pronouncement : 13-04-2017 O R D E R Shri S.S. Viswanethra Ravi, JM :- This appeal by the Revenue is against the order dt: 24-09- 2014 passed by the Commissioner of Income Tax…

Income Tax Officer-Ward-31(3), Kolkata vs. Dilip B Besai (HUF), Kolkata

In the result, the appeals of the revenue are dismissed

ITA 2799/KOL/2013[2006-2007]Status: DisposedITAT Kolkata27 Jan 2017AY 2006-2007

Bench: Hon’Ble Shri M.Balaganesh, Am & Shri S.S.Viswanethra Ravi, Jm]

For Appellant: Shri Nicholas Murmu, JCIT, Sr.DRFor Respondent: Shri Vijay Shah, FCA
Section 10(38)Section 143(3)Section 263

…be served by remanding the matter. We do not find any issue, which has remained unattended. For the aforesaid reasons, we hold that the judgment under challenge is not perverse." 4. The judgment in the case of Dalhousie Investment Trust Co. Ltd. v. CIT [1968] 68 ITR 486 (Sc) referred by the Assessing Officer does not assist the revenue because in that on appreciation of facts it was found as follows:— "On the facts, that the appellant dealt with the shares of McLeod and Co. and the allied companies as stock-in-trade, that they were in fact purchased even initially not as investments but for the purpose of sale at…

Dalhousie Investment Trust Co. Ltd. v. CIT (68 ITR 486) — Cited in 36 Judgments | BharatTax