added) 16. The decision of the Privy Council in the case of Punjab Co­operative Bank v. Commissioner of Income Tax9 is also very relevant. It was held thus: “The principle to be applied in such a case is now well settled. It was admirably stated in a Scottish case, Californian Copper Syndicate v. Harris [(1904) 6 F. 894 : 5 Tax Cas. 159.] and the statement has been more than once approved both in the House of Lords and in the Judicial Committee: See for example Commissioner of Taxes v. Melbourne Trust Ltd. [1914 A.C. 1001 at p. 1010.]. Some 9 (1940) SCC Online PC 46 Civil Appeal No.3291­3294 of 2009, etc. Page 36 of 45dicta which appear to support the view that it is necessary to prove that the taxpayer has carried on a separate or severable business of buying and selling investments with a view to profit in order to establish that profits made on the sale of investments are taxable, for example, the dicta in the case of Commissioners of Inland Revenue v. Scottish Automobile and