SAROJ KUMAR MAZUMDAR vs THE COMMISSIONER OF INCOME-TAX, WESTBENGAL, CALCUTTA.

The Supreme Court held that the single transaction of land sale by the appellant was not an adventure in the nature of trade under Section 10 of the Indian Income-tax Act, 1922. The Court emphasized that the onus was on the Department to prove the dominant intention of the appellant was to engage in trade, which they failed to do. Consequently, the appeal was allowed, reversing the decision of the Appellate Tribunal and affirming the Appellate Assistant Commissioner's findings regarding capital gains tax.