Summarize the following court judgment. Appeals Nos. 708 to 710 of 1966. Appeals by special leave from the judgment and order dated July 23	 1964 of the Andhra Pradesh High Court in Case Referred No. 42 of 1962. Sukumar Mitra	 Y. V. Anjaneyulu	 Bhuvnesh Kumari	 J. B. Dadachanji and O. C. Mathur	 for the appellant (in all the appeals). Niren De	 Solicitor General	 section K. Aiyar	 R. N. Sachthey and section P. Naya; 	 for the respondent (in all the appeals)	 The Judgment of the Court was delivered by Ramaswami	 J. These appeals are brought by special leave from the judgment of the High Court of Andhra Pradesh dated 23rd July	 1964 in referred case No. 42 of 1962. The assessment years involved in these appeals are and 1954 55	 the relevant accounting periods being the years ending 30 9 1948	 30 9 1952 and 30 9 1953	 respectively. The assessee firm Khan Bahadur Ahmed Alladin & Sons (hereinafter referred to as the 'assessee firm ') consists of three partners	 Khan Bahadur Ahmed Alladin	 and his two sons	 Khan Saheb Dost Mohammed Alladin and Noor Mohammed Alladin. The assessee firm purchased the Brengun Factory and the properties attached to it consisting of 403 acres of land	 14 factory buildings	 about on	 hundred residential quarters	 and railway sidings	 furnitures etc.	 in addition to the stores	 from the Government of India. The price of the Brengun Factory and the properties together with the furniture etc. was fixed at Rs. 27 lakhs while the price of the stores was fixed at Rs. 8 lakhs. During the relevant accounting years	 the assessee firm sold a part of the stores for Rs. 9	53	918 O.S. and 46 acres of land	 14 factory buildings	 furniture	 railway siding	 etc. for Rs. 26	48	215 O.S. It was not disputed that the excess over the price realised for the re	 sale of 441 stores was Rs. 2	26	484 O.S. and for the re sale of part of the factory land	 building etc. was Rs. 10	46	834 O.S. It was admitted by the assessee firm before the Appellate Tribunal that the surplus realised by the resale of stores was not a capital accretion but an adventure in the	 nature of trade. With regard to the factory it was argued that it was an investment	 and not an adventure in the nature of trade and as such the excess amount realised represented a realisation of capital asset. The contention of 	he assessee firm was rejected by the Income tax Officer	 by the Appellate Assistant Commissioner and by the Appellate Tribunal in appeal. The view taken by the Appellate Tribunal was that the assessee firm had planned a well calculated scheme of profit making	 that it had the intention of exploiting the properties which it had purchased to its advantage	 that the transactions in question constitute an adventure in the nature of trade	 and any surplus which it got by sale of the portions of the properties was liable to tax. At the instance of the assessee firm	 the Appellate Tribunal stated a case to the High Court on the following question of law : "Whether the purchase of the site and buildings known as "Brengun Factory" was in the course of a profit making scheme or an adventure in the nature of trade By its judgment dated 23rd July	 1964 the High Court	 answered the question against the assessee firm. On behalf of the appellant Mr. Sukumar Mitra argued that the assessee firm along with Abdullah Alladin	 brother of Khan Bahadur Ahmed Alladdin had been carrying on business as a partnership firm under the name of Khan Bahadur Ahmed Alladdin and Company (hereinafter referred to Alladdin & Co.). It had substantial interest in various joint stock companies	 and was the managing agent of several joint stock companies	 and possessed considerable financial resources. The assessee firm acquired the Brengun Factory with the intention of starting a bicycle factory or some other industry as an investment	 but not with the intention of resale. The argument was stressed that the purchase and sale of land and buildings was not in the line of business of the assessee firm. It was stated that the purchase was an isolated transaction and even after the sales	 a major portion of the factory remained with the assessee firm. It was contended that the	 assessee firm had not developed the land or parcelled it out with the view to sell it to purchasers as a residential area	 and make a profit. The submission made on behalf of the appellant was that the transaction of purchase was in the nature of investment and was not an adventure in the nature of trade and the sales represented the realisations of capital asset. 442 The provision of law under which assessment was made for the assessment year 1358 F. was section 31(3) of the Hyderabad Income Tax Act (hereinafter referred to as the 'Hyderabad Act ') which corresponds to section 23 (3) of the Indian Income Tax Act	 1922 (hereinafter referred to as the 'Indian Act). The mnents for the subsequent years were made under the Indian Act. The charging section under the Hyderabad Act is section 3	 which corresponds to section 4 of the Indian article The word "business is defined in section 3(1) of the Hyderabad Act which is identical with the language of section 2(4) of the Indian Act. Section 8 of the Hyderabad Act states : "Save as otherwise provided by this Act	 the following beads of income	 profits. and gains shall be chargeable to income tax in the manner hereinafter appearing	 namely (iv) Profits and gains of business	 profession or vocation". It corresponds to section 6 of the Indian Act. The question whether profit in a transaction is a capital accretion or has arisen out of an adventure in the nature of trade is a mixed question of law and fact. In Venkataswami Naidu & Co. vs Commissioner of Income tax(1) it was pointed out by this Court that the expression 'in the nature of trade in sub section (4) of section 2 of the Indian Act postulates the existence of certain elements in the adventure which in law would invest it with the character of trade or business : and that a Tribunal while considering the question whether a transaction is or is not an adventure in the nature of trade before arriving at its conclusion on the facts	 has. to address itself to the legal requirements associated with the concept of trade and business. In other words	 in reaching the conclusion that the transaction is an adventure in the nature of trade	 the Appellate Tribunal has to find the primary evidentiary facts and then apply the legal principle involved in the statutory expression "adventure in the nature of trade" used by section 2(4) of the Indian Act. A question of this description is a mixed question of law and fact and the decision of the Appellate Tribunal thereon is open to challenge under section 66 (1 ) of the Indian Act. The question whether the transaction is an adventure in the nature of trade must be decided on a consideration of all the relevant facts and circumstances which are proved in the particular case. The answer to the question does not depend upon the application of any abstract rule	 principle or formula but must (1) 443 depend upon the	 total impression and effect of all the relevant facts and circumstances established in the particular case. In Californian I Copper Syndicate vs Harris(1)	 Lord Justice Clerk observed	 "It is quite a well settled principle in dealing with questions of assessment of income tax that where the owner of an ordinary investment chooses to realise it	 and obtains a greater price for it than he originally acquired it at	 the enhanced price is not profit. . assessable to income tax. But it is equally well established that enhanced values. obtained from realisation or conversion of securities may be so assessable where what is done is not merely a realisation or change of investment	 but an act done	 in what is truly the carrying on	 or carrying out	 of a business. What is the line which separates the two classes of cases may be difficult to define	 and each case must be considered according to	 its facts; the question to be determined being Is the sum of gain that has been made a mere enhancement of value by realising a security or is it a gain made in the operation of business in carrying out a scheme for profit making ?" But in judging the character of such transactions several factors have been treated as significant in decided cases. For instance	 if a transaction is related to the business which is normally carried on by the assessee	 though not directly part of it	 an intention to launch upon an adventure in the nature of trade may readily be inferred. A similar inference would arise where a commodity is purchased and sub divided	 altered	 treated or repaired and sold or is converted into a different commodity and then sold. The magnitude of the transaction of purchase	 the nature of the commodity	 the subsequent dealings of the assessee the nature	 of the organisation employed by the assessee and the manner of disposal may be	 such that the transaction may be stamped with the character of a trading venture In Martin ' vs Lowry(2) the assessee purchased a large quantity of aeroplane linen and sold it in different lots	 and for the purpose of selling it started an advertising campaign rented offices	 engaged an advertising manager	 a linen expert and a staff of clerks	 maintained account books normally used by a trader	 and passed receipts and payment in connection with the linen through a separate banking account. It was held that the assessee carried an adventure in the nature of trade and so the profit was liable to be taxed. The same view was taken in Rutledge vs Commissioners of Inland Revenue(3) in regard to an assessee who purchased very cheaply a vast quantity of toilet paper and within a short time thereafter sold the whole consignment at a considerable profit. Similarly	 in Commissioners of Inland Revenue vs Fraser	 the assessee (4) a woodcutter bought for resale	 whisky in bond	 in three lots. He (1) T.C. 159	165 6. (2) 11 Tax Cases 297. (3) 14 Tax Cases 490. (4) 24 Tax Cases 498. 444 sold it later on at considerable profit. The assessee had never dealt in whisky before	 he had no special knowledge of the trade	 he did not take delivery of the whisky nor did he have it blended and advertised. Even so it was held that the transaction was not an adventure in the nature of trade. Lord President Normend observed in the course of the judgment : "It is in general. more easy to hold that a single transaction entered into by an individual in the line of his own trade (although not part and parcel of his ordinary business) is an adventure in the nature of trade than to hold that a transaction entered into by an individual outside the line of his own trade or occupation is an adventure in the nature of trade. But what is a good deal more important is the nature of the transaction with reference to the commodity dealt in. The individual who enters into a purchase of an article or commodity may have in view the resale of it at a profit	 and yet it may be that that is not the only purpose for which he purchased the article or the commodity	 nor the only purpose. to which he might turn it if favourable opportunity of sale does not occur. In some of	 the cases the purchase of a picture has been given as an illustration. An amateur may purchase a picture with a view to its resale at a profit	 and yet he may recognise at the time or afterwards that the possession of the picture will give him aesthetic enjoyment if lie is unable ultimately	 or at his chosen time	 to realise it at a profit. A man may purchase stocks and shares with a view to selling them at an early date at a profit but	 if he does so	 he is _purchasing something which is itself an investment	 a potential source of revenue to him while he holds it. A man may purchase land with a view to realising it at a profit	 but it also may yield him an income while he continues to hold it. If be continues to hold it	 there may be also a certain pride of possession. But the purchaser of a large quantity of commodity like whisky	 greatly in excess of what could be used by himself	 his family and friends a commodity which yields no pride of possession	 which cannot be turned to account except by a process of realisation	 I can scarcely consider to be other than an adventurer in a transaction in the nature of a trade; and I can find no single fact among those stated by the Commissioners which in any way traverses that view. In my opinion	 the fact that the transaction was not in the way of business (whatever it was) of the respondent in no way alters the character which almost necessarily belongs to a transaction like this". These are cases of commercial commodities but a transaction of purchase of land cannot be assumed without more to be an adventure in the nature of trade. In Leeming vs Jones("	 syndicate was formed to acquire an option over a rubber estate with a view to resell it at a profit	 and finding the estate too small the (1) 15 Tax Cases 333. 445 syndicate acquired ' another estate and sold the two estates on profit. It was held that the transaction was not in the nature of trade and the profit was not liable to be assessed to tax. The same view was expressed in Saroj Kumar Mazumdar vs Commissioner of Income tax West Bengal(1)	 in which the assessee who carried on business of engineering works purchased land which was tinder requisition by the Government	 negotiated a sale before the land was de requisitioned and sold it after the land was released. Again in Commissioners of Inland Revenue vs Reinhold(2) the respondent who carried on business of wharehousemen bought four houses in January	 1945	 and sold them at a profit in December	 1947. He admitted that he had bought the property with a view to resale and had instructed his agents to sell whenever a suitable opportunity arose. On behalf of the Crown it was contended that the purchase and sale constituted an adventure in the nature of trade and the profits	 arising therefrom were chargeable to income tax. It was	 held by the Court of Sessions that the initial intention of the respondent to purchase the property with a view to resell did not per se establish that the transaction was an adventure in the nature of trade and the Com missioners were justified in treating the profit as not assessable to income tax. But the circumstance of a particular case may lead to the conclusion that the purchase or resale of land is in the nature of trade. In Venkataswami Naidu 's (3 ) case the appellant firm which acted as managing agents purchased	 for a total consideration of Rs. 8	713 four contiguous plots of land adjacent to the place where	 the mills of the company managed by it were situated. The first purchase was made in October	 1941 and the second and subsequent purchases were made in November	 1941	 June	 1942 and November. 1.942. As long as the appellant was in possession of the land it made no effort	 to cultivate it or erect any superstructure on it but allowed the land to remain unutilised except for the rent received from the house which existed on one of the plots. The appellant sold the land to the company managed by it in two lots in September and November	 1947	 for a total consideration of Rs. 52	600. The question was whether the sum of Rs. 43	887 being the excess realised by the appellant by the two sales over its purchase price was assessable to income tax. The Appellate Tribunal rejected the contention of the appellant that the properties were bought as an investment and that the plots were acquired for building tenements for the labourers of the mills but came to the conclusion that the transaction was an adventure in the nature of trade. On a reference	 the High Court expressed the same view. It was held by this Court in appeal that the Appellate Tribunal was right in inferring that the appellant knew that it would be able (1) 37 Tax Cases 242. (3) sup.c.1/68 14 (2) 34 Tax Cases 189. 446 to sell the lands to the managed company whenever it thought it profitable so to do	 that the appellant purchased the four plots of land with the sole intention of selling them to the mills at a profit and that the High Court was right in holding that the transaction was an adventure in the nature of trade. As we have already said it is not possible to evolve any legal test or formula which can be applied in determining whether a transaction is 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 the transaction. What then are the material facts found in the present case ? Alladin & Co. was the managing agent of several joint stock companies viz.	 Hyderabad Asbestos Cement Products Limited (hereinafter referred to as the Asbestos Co.)	 Hyderabad Laminated Products Limited (hereinafter referred to as the Laminated Products)	 Hyderabad Allwyn Metal Works Limited (hereinafter referred to as the Allwyn Co.) and others. Alladdin & Co. started Asbestos Co. in 1946 and the Laminated Products in 1947. The Government of Hyderabad had 50% share holding in both these companies. Negotiations for the purchase of Brengun Factory situate in the out skirts of Hyderabad commenced in December	 1946. On 18th December	 1946	 there took place a meeting between Khan Saheb Dost Mohammed Alladin and Noor Mohammed Alladin on behalf of Alladin & Co. and Khan Bahadur Obaidullah	 the then Additional Financial Adviser to the Government of India. The latter informed the two Alladin brothers that the Government of India had decided to sell the Brengun Factory as the war had ended and it was going cheap. It was agreed that the price of the factory building should be fixed at Rs. 27 lakhs	 and of the stores at Rs. 9 lakhs. Alladdin & Co. asked for six months ' time for making the payment but finally it was agreed that the price should be paid in four equal monthly installments commencing from 1st January	 1947. The contract of sale was made subject to the condition that the Hyderabad Government was no longer interested in the factory and also subject to the confirmation by the Board of Directors. By its letter dated December 24	 1946	 Alladdin & Co. accepted the proposal and informed the Additional Financial Adviser that the Board had agreed to purchase the Brengun Factory and the first payment would be made on 1st or 2nd January	 1947. Not having ready cash to pay the first instalment the firm borrowed the sum from the State Bank and the Central Bank pledging the shares of the partners valued at about Rs. 20 lakhs for Rs. 9 lakhs. It is significant that the assessee firm invested very little of its own money in the purchase of the factory and the stores. It got six months 447 time from the Government of India to pay the price in instalments	 and paid it by pledging its shares with the Banks	 by obtaining further loan from the Banks on over drafts	 and by selling portions of the factory to the Asbestos Co. and Laminated Products	 and the Allwyn Co. The balance sheet of the assessee firm as on 31 9 1948 disclosed that the assessee firm owed about Rs. 7 lakhs to Government of India	 though by that time it had sold properties valued over Rs. 30 lakhs. It is a significant circumstance that on 23rd December	 1946 a meeting of the Board of Directors of the Asbestos Co. was held and in that meeting a resolution was passed that the Government should be approached in the matter of the valuation of the site and building in tile establishment of the "Asbestos Works" in the premises of the Brengun Factory purchased by the assessee firm and that the managing agents be authorised to address Nawab Medhi Nawaz Jung Bahadur in that behalf. The notice convening the meeting was issued on the 23rd December	 1946	 on which date	 the assessee .firm had not even intimated their acceptance of offer made by the Government of India for the sale of Brengun Factory. Pursuant to the resolution of 28th December	 1946	 the Asbestos Co. resolved to purchase 14 acres of land	 buildings etc. for Rs. 5 lakhs. It should be noticed that the valuation by the P.W.D. which was considered necessary on the 28th December	 1946 was given up and the price of Rs. 5 lakhs was accepted by the Board of Directors. In the circumstances	 the inference that that resolution was passed at the instance of the assessee firm is not unreasonable. Pursuant to the resolution a sale deed appears to have been executed in favour of the Asbestos Company on 31st March	 1947. It is apparent that the interval of time between the purchase of the factory and the sale was about 3 months	 and this is hardly consistent with the contention of the assessee firm	 that it had purchased the property as an investment. It is also admitted that the sale deed in favour of the Asbestos Co. as well as the Laminated Products and Allwyn Co. were executed by the Government of India in their favour direct. The sale was in favour of the Laminated Products pursuant to a resolution passed on 17th September	 1947. On that day the company resolved that in view of the special facilities for power	 water and railway siding at the Alladin Industrial Estate	 Sanathnagar	 sanction should be accorded for the acquisition of the	 proposed area of 8 acres of land for the location of the company 's factory as per the rate offered to the company i.e.	 at O.S. Rs. 5	000 per acre and a sum of Rs. 40	000 was agreed to be paid towards the price. A sale deed was executed pursuant to the resolution in June	 1948. The next transaction relates to the purchase by the Allwyn Co. The Board of Directors at its meeting on October 29	 1947	 resolved to sell away their existing factory buildings at Azamabad to the Nizam 's State Railway	 and purchase the new factory	 448 land and buildings as Sanathagar	 for Rs. 25 lakhs. The property purchased consisted of 24 acres	 of land	 factory buildings 		Ind furniture	 and the sale deed was executed on February 11	 1948. It is manifest that within one year of the purchase of the Brengun Factory	 the assessee firm realised Rs. 13	99	753 by the sale of stores and Rs. 33	90	908 by the sale of 46 acres of land and buildings	 in all making a profit of Rs. 11	90	661. It appears from the balance sheet as on September 30	 1948 that even after the extended date	 it still owed Rs. 7 lakhs to the Government though by that time it had sold over Rs. 30 lakhs worth of property. The assessee firm was thus paying off the dues to the Government and also discharging its debts by selling fractions of the property. In other words	 the assessee firm was purchasing	 selling and liquidating the loans	 which would all show the commercial nature of the transaction. These facts establish that the assessee firm had not enough financial resources to invest Rs. 36 lakhs on the. Bren Gun Factory and that the transaction was launched upon with a view to make profit and not as a permanent investment. There is another aspect of the matter to be taken into account. The property income from Bren Gun fac :tory during the year 1953 54 as would appear from the Assessment Orders of the years	 1953 54	 1954 55 was about Rs. 22	000 I.G. The interest on loans on over drafts is paid to be 41 per cent. on 27 lakhs the balance of price payable to the Government	 the :annual interest would be about Rs. 1	21	500. It is manifest that the assessee firm could not have borrowed the money to purchase the property as an investment when the income was about 1/6 of the interest payable on the amount borrowed. Mr. Sukumar Mitra suggested that the assessee firm intended to develop the Bren Gun Factory as an Industrial Estate and referred to certain correspondence in this connection. But the correspondence does not establish that any of the foreign companies agreed to start a cycle factory of their own or in collaboration with the assessee firm. The correspondence between the parties admittedly ended in February 1946. Mr. Sukumar Mitra also referred to the correspondence between January 8	 1947 to March 10	 1947 but this also does not show that there was any prospect of the assessee firm starting a cycle industry or any other industry either solely .or in collaboration with a foreign company. Having regard to total effect of all the relevant facts and circumstances established in this case we are of the opinion that the High Court was right in its conclusion that the purchase of the site and the buildings of the Bren Gun Factory was an adventure in. the nature of trade and was in the course of a profit making scheme and the question was rightly answered by the High Court .against the assessee firm. 449 We consider it necessary to add that the statement of the case made by the Appellate Tribunal is unsatisfactory and gives no information whatever about the arguments respectively advanced by the parties or the findings recorded by the Appellate Tribunal. The statement of the case is not intended to be mere copy of the order sheet in a litigation but it must set out the points raised by the aggrieved party	 the reply thereto	 if any and the authorities or statutory provisions relied upon for the view taken by the Appellate Tribunal together with an intelligible summary of the facts found by the Appellate Tribunal. A statement of the case should fully	 clearly and precisely set out all the relevant facts	 or if the facts have been fully set out in the judgment of the Tribunal they may be incorporated in the statement of the case by a reference to particular paragraphs of the judgment in which the facts are so set out. In any event	 it is important that the Appellate Tribunal should state clearly its conclusions and findings of fact and should not leave it to the High Court or this Court to deduce the findings or to collect the facts from a large number of documents which are part of the record of the case. A statement of the case which does not set out precisely the findings of the Appellate Tribunal on the questions of law and fact serves no 'useful purpose. It merely gives an opportunity to the parties to put forward arguments at the stage of reference which are often untenable	 For the reasons already expressed we hold that these appeals must be dismissed with costs. There will be one hearing fee. G.C. Appeals dismissed.

The assessee firm purchased a Brengun factory from the Government of India and sold the stores and part of the lands and buildings shortly afterwards At a higher price. It admitted before the Income tax authorities that the purchase and sale in respect of the stores constituted an adventure in the nature of trade	 but in respect of the land and buildings sold it contended that they had been purchased by way of investment	 and the sale of a part of them did not result in assessable profit. The claim was rejected by the Income tax Officer	 by the Appellate Commissioner	 and by the Appellate Tribunal. The High Court in a reference under a. 66(1) also rejected it. The firm appealed to this Court by special leave. HELD : (i) In reaching the conclusion that a transaction is an adventure in the nature of trade	 the Appellate Tribunal has to find the primary evidentiary facts and then apply the legal principle involved in the statutory expression "adventure in the nature of trade		 used in section 2(4) of the Indian Income tax Act. A question of this description is a mixed question of law and fact and the decision of the Appellate Tribunal thereon is open to challenge under section 66(1) of the Act. [442 F G] (ii) The question whether the transaction is an adventure in the nature of trade must be decided on a consideration of all the relevant facts and circumstances which are proved in the particular case. The answer to the question does not depend on the application of any abstract rule	 principle or formula but must depend upon the total impression and effect of all the relevant facts and circumstances established in the particular case. [442 H] (iii) In the present case the appellant firm purchased the Brengun factory from borrowed money. The income from the property was only about 1/6 of the interest payable by the company on the money borrowed. The first sale was effected by the firm within three months of the purchase. and the sums received from sale were utilised for paying off the debts as also the dues to the Government. The firm had not enough financial resources to invest the money required to purchase the factory and the transaction could not therefore be with a view to making a permanent investment	 but only for making profit. It had not been established by evidence that the appellant firm purchased the Brengun factory for purpose of establishing a cycle factory. Having regard to the total effect of all the relevant facts and circumstances established in the case it was rightly held by the High Court that the transaction was an adventure in the nature of trade and part of a profit making scheme. [448 B H] (iv) The statement of case is not intended to be a mere copy of the order sheet in a litigation but it must set out the points raised by the .aggrieved party	 the reply thereto	 if any	 and the authorities or statutory 440 provisions relied upon for the view taken by the Appellate Tribunal together with an intelligible summary of the facts found by the Appellate Tribunal. The Tribunal should clearly state its conclusions and findings of fact and should not leave it to the High Court or this Court to deduce the findings or to collect facts from a large number of documents which are part of the record of the case. [449 A D] Vankataswami Naidu & Co. vs Commissioner of Income tax	 	 Californian Copper Syndicate vs Harris	 5 T.C. 159	 Martin vs Lowry	 I I T.C. 297	 Rutledge vs Commissioners of Inland Revenue	 14 Tax Cases 490	 Commissioners of Inland Revenue vs Fraser	 the assessee. 24 Tax Cases 498	 Leeming vs Jones	 15 Tax Cases 333	 Saroj Kumar Mazumdar vs Commissioner Income tax	 West Bengal	 and Commissioners of Inland Revenue vs Reinhold	 34 Tax Cases 389	 referred to.