Dismissing the appeal of the Revenue the  Tribunal held that  the assessee had only allowed his name to be used in the transactions and was personally involved in the making of these deals. The income earned by the assessee was not an appreciation of his investment, but consideration for being part of the arrangement to earn profit from transactions involving lands. The income earned was towards his personal involvement and for time contributed. There was no transfer of capital asset by the assessee. The amounts were invested by SDP and 90 per cent. of the profits made on the two transactions was remitted to his account. SDP had disclosed the profits made from these two transactions in his return of income under the head “Business income” which had been accepted under section 143(3). Principles of uniformity demanded that the balance 10 per cent. also to be taxed as “Business income” in the hands of the assessee.(AY.2011-12)