Tribunal held that the assessee having held the land for well over five years before selling the same, the obvious intention of the assessee was to make investment for capital appreciation and, therefore, the profits earned has to be considered as capital gains; simply because the piece of land has been bifurcated into five different parts to make it saleable after a long period of five years from the date of investment, per se cannot grant the character of stock-in-trade so as to give it a colour of business activity. Followed, Jankiram Bahadur Ram v. CIT (1965) 57 ITR 21 (SC), CIT v. Kasturi Estates (P) Ltd. (1966) 62 ITR 578 (Mad), CIT v. Holck Larsen (1986) 58 CTR  53 /  160 ITR 67 (SC) and Asstt. CIT v. Ashok Motilal Kataria (2009) 308 ITR 298 (Pune (Trib)   G. Venkataswami Naidu & Co. v. CIT (1959) 35 ITR 594 (SC)  (AY.2014-15)