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commissioner of income tax-iv Vs. m/s devasan investment pvt. ltd.
April, 21st 2014
                                  RESERVED ON: 21.03.2014
                                PRONOUNCED ON: 16.04.2014

                   ITAs 1102/2011 & 1103/2011

+     ITA 1102/2011


                     Through : Mr. N.P. Sahni, Advocate.



                     Through : Mr. Ajay Vohra with Ms. Kavita
                     Jha and Mr. Vaibhav Kulkarni, Advocates.

+     ITA 1103/2011


                     Through : Mr. N.P. Sahni, Advocate.



                     Through : Mr. Ajay Vohra with Ms. Kavita
                     Jha and Mr. Vaibhav Kulkarni, Advocates.


ITAs 1102/2011 & 1103/2011                                 Page 1

1.    In these appeals, the Revenue contends that the Income Tax
Appellate Tribunal ("ITAT") erred in concluding that the amounts
originally brought to tax as business income of the assessee were
short and long term capital gains as claimed in the returns filed.
The following common question of law arises in both appeals:

      Did the ITAT fall into error in endorsing the
      decision of the CIT (A) that the sum of ` 35,75, 908/-
      short term capital gain (for 2006-07) claimed by the
      assessee and ` 1,43,43,154/- (for 2007-08) was not
      business income
2.    The Assessing Officer ("AO") assessed the short term
capital gains on sale of shares at `35,75, 908/- (for 2006-07)
claimed by the assessee and ` 1,43,43,154/- (for 2007-08) as
business income. On the other hand he accepted the gain on of
Mutual Funds as short term capital gain/long term capital gains. In
the proceedings before AO, in respect of 2006-07 the assessee's
contentions were rejected, on the basis that that the assessee was
doing frequent transactions for sale and purchase of shares; that on
six occasions, the assessee had purchased shares of MIs, Monnet
Ispat Ltd and on nine occasions, the assessee had made sales of this
scrip, which meant that the sale-purchase was spread over the
whole year; similarly, the assessee had purchased of shares of ING
Vysya Bank Ltd. on four occasions and had transacted sales on two
occasions. Thus, these activities, along with other facts of the case
showed that its motive was to earn profit from sale and purchase of

ITAs 1102/2011 & 1103/2011                                     Page 2
shares and not to earn dividends. The AO agreed with the assessee
that the gain on Mutual Funds was gain on investment as units
could not be purchased-sold in the open market. The gains from the
purchase-sale of units of Mutual Funds were accepted by the
assessee as income from capital gains, over long term or short
term. By the CIT(A)'s order, the AO was directed to treat the
income of Rs. 35,75,908/- as short term capital gain instead of
business income, as done by the AO.

3.    For 2007-08, it had been contended that the funds invested in
MFs were investments, and not stock in trade, and that they were
not tradable in the stock exchange but had to be redeemed. Thus,
the profits were not business profits. The sum of ` 12,70,710/- was
LTCG and `34,56,000/- was STCG. It was also contended that the
assessee had invested in only 9 scrips during the year and a total
purchase/sale of ` 3 crore was made. Reliance was placed on the
fact that in the preceding year, 2005-06, similar treatment was
accepted. The net owned funds of the assessee were ` 7.32 crore.
It was contended that in Schedule III to the audited accounts, the
company had disclosed the investment: of `4.58 crores, ` 2.5
crores were kept in investment, in terms of the company's Board
resolutions. The AO, however, directed that the amounts be treated
as business income in the assessee's hands. The l atter, therefore,
appealed to the Commissioner (Appeals). That appeal succeeded.

ITAs 1102/2011 & 1103/2011                                   Page 3
4.    Since the revenue lost both appeals for AY 2006-7 and
2007-08 before the Appellate Commissioner, feeling aggrieved it
appealed to the ITAT, which dismissed its appeals for both years. It
has, therefore, preferred the present appeals.

5.    The revenue contends that the assessee failed to keep
separate accounts for investments and normal trading activities.
Relying on the decisions, especially in Commissioner of Income
Tax v. Associated Industrial Development Company, 82 ITR 586
(SC), it was contended that the volume, frequency and quantum
test as well as whether the assessee maintains separate investment
accounts is a strong indicator to examine whether the profit is
capital gain or income from business. It was contended that the
assessee is engaged in the business of a share broker. Its
investments in the impugned transactions were clearly part of its
trading activities, not only because there were no separate
accounts, but also because frequent sale and purchase of shares of
few companies had been resorted to. The decision in Commissioner
of Income Tax v. P. Manomani, 245 ITR 48 (Mad) and
Commissioner of Income Tax v. Malabar Investment Co., 320 ITR
486 (Kar) were relied on. Relying on the reasoning of the AO, it
was argued that the pattern of share acquisition and share clearly
showed that the assessee's intention was to trade or conduct
business and not to hold the scrips for investment. Had the
intention been genuinely to invest in such shares, the assessee

ITAs 1102/2011 & 1103/2011                                    Page 4
would have taken the trouble of keeping a separate investment

6.    It was argued that the AO's finding of fact that there were 40
transactions of sale and purchase of shares and the duration of
holding were as short as 10 days clearly proved that the assessee's
intention was to engage itself as trader in the normal line of
business activity, and not invest these sums. The assessee was
transferring shares from stock­in-trade account to investment
account according to its sweet will. During the year 2004-05
relevant to Assessing Year 2005-06, the assessee transferred stock-
in-trade amounting to Rs. 1,77,540 140 to investment account. This
indicated the intention of assessee, that they were only classifying
these shares as investment only to avoid tax incidence. It was also
contended that the decision in Raja Bahadur Visheshwar Singh v.
CIT, (1961) 41 ITR 685 (SC) would apply to the facts of this case,
to establish that in fact the use of funds without a clear
demarcation, and free transfer from stock in trade account revealed
that the assessee's intention was to trade in the shares. Relying on
Commissioner of Income Tax v. NSS Investments Ltd, 2007 (277)
ITR 149 (Mad) it was contended that the objects of the assessee
company were to trade in shares. Since it held the shares which
were sold, in question, as stock in trade, it was but legitimate that
profit out of such sale should be treated as business income and not
as capital gains.

ITAs 1102/2011 & 1103/2011                                     Page 5
7.    It was contended on behalf of the assessee, that whilst there
is no quarrel with the proposition that whether a particular
transaction has resulted in business income or sale of capital asset
is a question of intention, the fact remains that each transaction has
to be analysed by the authority and no generalized conclusion
based on stereotypes can be reached. It was argued that the mere
circumstance that the amounts used were not specifically sourced
from investment account did not absolve the Revenue from the task
of unravelling the nature of the transaction. It was submitted that if
the Revenue were correct, then investment and share dealing
companies would be placed at a disadvantage and discriminated
against. There cannot be a rule ­ at least there is no statutory basis
for holding- that such companies cannot or do not invest. Like
business and trading concerns which engage themselves in other
business activities, share brokers and dealers too can, and do,
8.    It was submitted that primacy to no single factor or aspect
can be given, and an overall effect of the various indicia have to be
taken into consideration by the court. Whilst in a given case, the
volume frequency, and duration of holding test could be crucial, in
another it might well be that the line of business of a concern is not
to indulge in share trading activity; in yet another, the fact that
share trading is indulged in with borrowed (as opposed to own)
funds, could be the dispositive consideration. It was submitted that,
therefore, the straightjacket approach adopted by the AO ­ basing
himself on the sole fact that demarcation of funds was not made in

ITAs 1102/2011 & 1103/2011                                      Page 6
the assessment year, cannot be upheld. Learned counsel here
emphasized that the overemphasis on the holding of share only for
10 days was unjustified because that was in respect of one
transaction, which the Commissioner in the appellate order had
analysed in detail and concluded that the shares had been
subdivided into separate lots of lesser value; they were acquired the
previous year and sold later during the assessment year in question.
9.    The main reasoning of the ITAT can be found in the
following extract of its impugned order, which earlier recorded the
contentions of the parties, analyzed the nature of the transactions,
and took note of the case law cited:
      26. We are unable to see as to how this decision
      runs counter tó the case of the assessee. First of all,
      the substantial nature of transactions has been laid
      bare by the assessee before the Department right
      from the word "go", as deliberated upon in the
      preceding paragraphs. The holding of shares was by
      way of investment. The activity was in accordance
      with the main objective of the assessee company. It
      was duly authorized by the Memorandum and
      Articles of Association of the assessee company. The
      shares were purchased out of the assessees own
      funds and not borrowed funds. The decision of
      investment of the assessee's shareholder's funds ¡n
      share/units and Mutual Funds was taken by the
      management of the assessee company from time to
      time with the objective of capital appreciation in the
      long term and in case the target price was achieved
      in the short run, the shares were to be sold in the
      market. It was depending on the funds available,
      that the management of the assessee company
      decided which shares were to be acquired. The
      investment was shown as such in the balance sheet

ITAs 1102/2011 & 1103/2011                                      Page 7
      of the assessee company, under Schedule Ill of the
      audited accounts. The AO had also misconstrued the
      volume of share transactions. Undisputedly, the
      assessee dealt in only nine scripts during the entire
      year. This included 17 transactions of share
      purchases and 22 transactions of share sales,
      aggregating to 40 transactions in ten days, which,
      by no stretch of imagination, can be said to be a
      high frequency of transactions. Therefore, "Fidelity
      North Star Fund & Other In re" (supra), also does
      not act in any manner detrimental to the case of the

Analysis & Findings

10.   The above discussion brings to the fore the question what
factors are to be given weight while examining whether a taxpayer
is a dealer in shares or having regard to the nature of investment, it
is to be construed that the income bears the character of sale of a
capital asset so as to attract capital gains tax ­ either STCG or
LTCG. In Commissioner of Income Tax, U.P v. Madan Gopal
Radhey Lal, [1969] 73 ITR 652 (SC) the Supreme Court dealt with
the issue, and discussed the question:

      "A trader may acquire a commodity in which he is
      dealing for his own purposes, and hold it apart from
      the stock-in-trade of his business. There is no
      presumption that every acquisition by a dealer in a
      particular commodity is acquisition for the purpose
      of his business; in each case the question is one of
      intention to be gathered from the evidence of
      conduct and dealings by the acquirer with the

ITAs 1102/2011 & 1103/2011                                      Page 8
In Associated Industrial Development (supra) the Supreme Court
observed as follows:

      " was open to the assessee to contend that even
      on the assumption that it had become a dealer and
      was no longer an investor in shares the particular
      holdings which had been cleared and the sales of
      which had resulted in the profit in question had
      always been treated by it as an investment. It can
      hardly be disputed that there was no bar to a dealer
      investing in shares. But then the matter does hot rest
      purely on the technical question of onus which
      undoubtedly is initially on the revenue to prove that
      a particular item of receipt is taxable. Whether a
      particular holding of shares is by way of investment
      or forms part of the stock-in-trade is a matter which
      is within the knowledge, of the assessee who holds
      the shares and it should, in normal circumstances,
      be in a position to produce evidence 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."

In Vijaya Bank Ltd. v. Additional Commissioner of Income-tax,
Bangalore, AIR 1991 SC 239 the Supreme Court dealt with a
situation where the assessee-bank, had received amounts on
securities purchased from another bank company as well as in the
open market. The two amounts were brought to tax by the AO
overruling the assessee's claim that they were deductible. The High
Court, on a reference, observed that the amount spent by the
assessee for the purchase of securities were in the nature of capital
outlay and they could not be set off as expenditure against income

ITAs 1102/2011 & 1103/2011                                     Page 9
accruing on the securities. In that context, the Supreme Court held
as follows: -

      "In the instant case, the assessee purchased
      securities. It is contended that the price paid for the
      securities was determined with reference to their
      actual value as well as the interest which had
      accrued on them till the date of purchase. But the
      fact is, whatever was the consideration which
      prompted the assessee to purchase the securities, the
      price paid for them was in the nature of a capital
      outlay, and no part of it can be set off as expenditure
      against income accruing on those securities.
      Subsequently when these securities yielded income
      by way of interest, such income was attracted by
      Section 18.

      Claim for deduction can be sustained only when the
      assessee is in a position to show that any reasonable
      expenditure had been incurred for the purpose of
      realising the interest on securities. The amounts
      claimed by the assessee for deduction are not shown
      to have been expended for the purpose of realising
      the interest, and are therefore not allowable as
      deductible expenditure."

11.   P.M. Mohammed Meerakhan v. Commissioner of Income-
tax, Kerala, 73 ITR 735 (SC) another ruling of the Supreme Court
reiterated that it was not 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

ITAs 1102/2011 & 1103/2011                                      Page 10
the transaction. Likewise, in Raja Bahadur Kamakhya Narain
Singh (supra) the question of adventure in the nature of trade was
again considered by the Supreme Court and which 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
brings 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.

12.    The Madras High Court in N.S.S. Investments (P) Ltd.
(supra) had to deal with the question whether on the facts and in
the circumstances of the case, the ITAT erred in holding that the
profit on sale of shares was to be treated as capital gains instead of

ITAs 1102/2011 & 1103/2011                                     Page 11
business income. The Court referred to paragraph 15 of the ITAT
order and then stated as follows: -

      "The finding of fact recorded in para 15 of the order
      of the Tribunal is that the shares in question were
      never treated by the assessee as stock-in-trade and
      they were held for earning dividend only. A
      company can hold some shares as stock-in- trade for
      the purpose of doing business of buying and sale of
      such shares, while at the same time it can also hold
      some other shares as its capital for the purpose of
      earning dividend income. Here the shares in
      question were held as the assessee's capital and not
      as stock-in-trade. Hence, there would be capital
      gain and not business income. Hence, we answer the
      question referred in the affirmative i.e., in favour of
      the assessee and against the Department."

13.   In Commissioner of Income Tax v. Gulmohar Finance Ltd.,
[2008] 170 Taxman 483 (Delhi), this Court observed as follows:

      "It was noted by the Tribunal that in earlier
      assessment years, the assessee had shown the shares
      held in BT Tech Net Ltd. as investment right from
      the date of purchase and this was shown as such in
      the balance sheet of the assessee, which was filed
      along with the return of income. No objection was
      taken to this position in the earlier years. However,
      the Commissioner has now decided that it was not
      an investment without there being any change in
      facts and therefore, the Tribunal held that there was
      no occasion for the Commissioner to take a contrary
      view than what was disclosed and accepted on
      earlier occasions. Even on merits, the Tribunal
      came to the conclusion that the shares held by the
      assessee in BT Tech Net Ltd were an investment and
      therefore, any profit earned on the sale thereof is

ITAs 1102/2011 & 1103/2011                                      Page 12
      required to be treated as capital gains. Whether the
      shares were held by the assessee as an investment or
      stock-in-trade is a matter of fact and we do not find
      any perversity in the view taken by the Tribunal that
      the shares were held as an investment."

14.   The Circular issued by the Central Board of Direct Taxes
(CBDT) on 15th June, 2007 notes several rulings, notably
Associated Industrial, Commissioner of Income-tax, Bombay and
Commissioner of Income Tax v. H. Holck Larsen, [1986] 160 ITR
67 (SC), and goes on to deal with what should be the test to see if
shares are held as stock-in-trade or as investments. The following
guidelines were given:

      "10. CBDT also wishes to emphasise that it is
      possible for a taxpayer to have two portfolios, i.e.,
      an investment portfolio comprising of securities
      which are to be treated as capital assets and a
      trading portfolio comprising of stock-in-trade which
      are to be treated as trading assets. Where an
      assessee has two portfolios, the assessee may have
      income under both heads, i.e., capital gains as well
      as business income.

      11. Assessing Officers are advised that the above
      principles should guide them in determining
      whether, in a given case, the shares are held by the
      assessee as investment (and therefore giving rise to
      capital gains) or as stock-in-trade (and therefore
      giving rise to business profits). The Assessing
      Officers are further advised that no single principle
      would be decisive and the total effect of all the
      principles should be considered to determine
      whether, in a given case, the shares are held by the
      assessee as investment or stock-in-trade."

ITAs 1102/2011 & 1103/2011                                    Page 13
15.   In 2007-08 the assessee company in its P&L Account, for
year ending 31.03.2007, showed profit on sale of investment of `
1,57,29400/-. In its return of income, the assessee has shown long
term capital gain of ` 1,47,2151/- which was claimed as exempt
under Section 10 (38) of the Income Tax Act. The assessee claimed
short term capital gain of ` 1,43,43,154/- on which tax was been
paid under Section 111A of the Income Tax Act, 1961. The AO
had raised a query why income from STCG/L TCG should not be
treated as business income. The assessee claimed that funds
invested in Mutual Funds and Equity Shares on which capital gains
have been received were investments and could not be treated as
Stock in Trade. The units were not tradable on the stock exchange
and had to be redeemed by such Fund houses; thus profits thereon
could not possibly be treated as business income. Similarly,
investments were made in shares. During the whole year the
company dealt with in only 11 scrips. The total sale consideration
during the year was ` 5.56 crore only and there were no frequent
transactions. Therefore capital gain on shares of ` 1.43 crores was
not business profit. The assessee company is had net owned funds
of Rs. 9.41 crores as on 31-03-2007 as per details hereunder:-
             Share Capital                 Reserves and Surplus

             46.25 lakhs                    895.09 lakhs
             TOTAL:                         941.34 lacs

ITAs 1102/2011 & 1103/2011                                             Page 14
16.   As on 31-03-2007 the assessee company had made
investments of Rs. 4.61 crores in terms of the following details:

      Investment in .Shares            Investment in Mutual Funds

                259.53 lacs                   201.00 lacs

                TOTAL:                        460.53 lacs

The assessee invested its shareholders' funds in shares/units of
mutual funds in terms of the decision of its management from time
to time. These were made in mutual fund units and shares. Whilst
the investments were not demarcated and sourced through separate
accounts, equally the fact remains that the objects of the company
permitted such transactions. What is more, there were only 11 sale
and purchase of scrips ­ these did not indicate any great volume or
frequency of share/purchase transactions. Keeping in mind the
ruling in Associated Industrial (supra) as well as other decisions
that undue emphasis cannot be given on one indicating factor
alone, the findings of fact arrived at by the Commissioner
(Appeals) and confirmed by the ITAT, in the impugned order, in
this Court's opinion, do not disclose any error so as to call for
17.   So far as AY 2006-07 is concerned, this Court notices that
the AO had in his order accepted that the gains derived out of sale
of mutual funds could not be said to constitute business income.
However, he was considerably influenced by the profit in respect
of sale of shares, to the extent of ` 35,75, 908/-, which, according

ITAs 1102/2011 & 1103/2011                                    Page 15
to him, on analysis of the facts, was business income. One of the
primary reasons for his conclusion was the short duration- to the
extent of the holding period of 10 days. The assessee counters the
revenue's submissions here arguing that the shares had been
purchased out of its own funds; the activity was duly authorized by
its Memorandum of Articles of Association. As regards the volume
of share transactions, the assessee points out that it had dealt in
only nine scripts during the entire year, which included 17 share
purchase transactions and 22 sale transactions during the year,
totaling to 40 transactions in all during the entire year, i.e., one
transaction in 10 days. This was not a very high frequency of
transactions. The assessee also received dividend on the shares held
by it; and its infrastructure was small, whereas the business activity
required a much larger infrastructure.
18.   The suspect transaction in question, i.e sale and purchase of
Monnet Ispat shares, was gone into in some detail by the
Commissioner (Appeals) after which it was concluded that the
nature of the transaction was essentially as investment,
notwithstanding that the purchase and sale took place in a short
duration. The rationale for this appeared to be that the assessee
kept a "target" price for the shares, before it. As long as such target
was not achieved, the assessee had decided to hold the shares. In
this particular instance, the target appeared to have been achieved
within one or two months. The following chart is extracted from
the order of the Commissioner (Appeals):

ITAs 1102/2011 & 1103/2011                                      Page 16
Before this Court, the assessee pointed out that in all about 27,000
shares were all acquired in January 2006. Even though they were
on different dates, the proximity of their acquisition was because
one purchase order was given, but the delivery of shares was based

ITAs 1102/2011 & 1103/2011                                   Page 17
on their availability, which was on different dates. All these shares
were sold after a month, and in some cases about 45 days.
This Court notices that for 2006-07 the total share consideration
was Rs. 3.4 crores, as against Rs. 4.58 for the previous year.
Furthermore, the assessee had its own funds to the tune of Rs. 7.31
crores, in the form of shareholder's funds. Further, dividend
income to the extent of Rs. 1.12 crore was also earned. The
Commissioner found that during the year, there was no transfer
from stock in trade to investment account and that the transfers had
been accepted during the year 2005-06. Keeping all these aspects
in mind, it was held that the income derived from sale of shares
was, for 2006-07, not business income but capital gains.
19.   As    in   the   case   of   AY    2007-08,     the   Appellate
Commissioner's evaluation of facts was based on an overall
consideration of all the circumstances. As emphasized in H. Holck
Larsen and P. Mohammed Mirakhan (supra) by the Supreme
Court, no single factor or criteria ought to be given undue weight,
ordinarily. Having regard to the entire facts, the court is satisfied
that on a fair application of the various tests, viz the volume,
frequency and duration of holding test; the source of funds (own or
borrowed); the objects ­ of the enterprise- test; the nature of the
assessee's business; the previous history of such transactions, etc
the conclusions of the Commissioner, endorsed by the ITAT after
its independent analysis of the circumstances, does not disclose any
error of law warranting interference by this Court.
20.   For the foregoing reasons, the question of law framed is

ITAs 1102/2011 & 1103/2011                                    Page 18
answered in favour of the assessee and against the revenue. The
appeals are consequently dismissed without any order as to costs.

                                           S. RAVINDRA BHAT

                                                R.V. EASWAR
APRIL 16, 2014

ITAs 1102/2011 & 1103/2011                                  Page 19
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