11 Apr 2025
CAC INTERNATIONAL LTD v. COMMISSIONER OF INLAND REVENUE
- Citation
- [2025] HKCFI 1366
- Court
- Court of First Instance
- Case number
- HCIA4/2022
The Board of Review correctly conducted a de novo assessment of the evidence and, having assessed badges of trade and objective circumstances (frequency and intensity of transactions, short holding periods, financing and profits), correctly found the appellant acquired the properties with the intention of disposing of them for profit; any isolated use of the phrase ‘true and only reasonable conclusion’ did not demonstrate the application of an erroneous standard of proof and did not vitiate the Board’s substantive findings. The appeal is dismissed.