Dismissing the appeal of the revenue the Court held that ,  the Assessing Officer had merely proceeded on the basis that the origin of the bonus shares being the shares held by the assessee by way of stock-in-trade, necessarily the bonus shares would also partake of the same character. The Tribunal was justified in the facts and circumstances of the case in treating the bonus shares as investments.  Court also held that in  CIT v. Madan Gopal Radhey Lal [1969] 73 ITR 652 (SC) the Court observed that bonus shares would normally be deemed to be distributed by the company as capital and the shareholder receives the shares as capital. The bonus shares are accretions to the shares in respect of which they are issued, but on that account those shares do not become stock-in-trade of the business of the shareholder. A trader may acquire a commodity in which he is dealing for his own purposes and hold it apart from the stock-in-trade of his business. There is no presumption that every acquisition by a dealer in a particular commodity is acquisition for the purpose of his business ; in each case the question is one of intention to be gathered from the evidence of conduct and dealings by the acquirer with the commodity. ( AY.2006-07 to 2009-10)