DALMIA CEMENT LIMITED vs COMMISSIONER OF INCOME TAX, NEW DELHI

The Supreme Court held that a single and isolated transaction can qualify as a business transaction under Section 2(4) of the Income Tax Act, 1922, if it exhibits clear indicia of trade. The Court ruled that the onus of proving that such a transaction is in the nature of trade lies with the Taxation Department. The appellant's intention to sell imported machinery for profit, despite it being a single transaction, established it as an adventure in the nature of trade, affirming the Tax Officer's assessment.