10 Oct 1989
THE COMMISSIONER OF INLAND REVENUE v. WAYLEE INVESTMENT LTD
- Citation
- THE COMMISSIONER OF INLAND REVENUE v. WAYLEE INVESTMENT LTD
- Court
- Court of Appeal
- Case number
- CACV6/1989
The Court held the profit was revenue in nature because the respondents acquired and held the shares as part of a Bank group rescue operation with the predominant purpose of protecting the Bank's loan and realising a profit when conditions permitted; the respondents acted as a group vehicle and the shares constituted trading stock (an adventure in the nature of trade). The Board of Review's contrary conclusion was positively wrong in law and the profits tax assessment was restored.