Section 2(47) & 45 of the Income-tax Act, 1961—Capital gain—Mere passive nature of income can't be a sole criteria for disallowance of expenses and before arriving at such a conclusion, there are certain matters which need appropriate consideration, the assessee may be a conservative investor and may not have invested in mutual funds, stock market or private equity, however, the same cannot be held against him unless the considerations are examined in detail, thus,it was appropriate to remand the matter back to the file of the Assessing officer to examine the same afresh including the decision of the Coordinate Bench after providing reasonable opportunity to the assessee - ACIT V/s IJYARAJ SINGH - [2020] 183 ITD 237 (ITAT-JAIPUR)