Development of infrastructure alone (for example, the division of land into plots, the construction of access roads, the installation of mains services) is not sufficient to demonstrate the appropriation of land, previously acquired as a capital asset, to stock in trade and does not automatically allow us to argue supervening trading. Such development merely enhances the value of the capital asset in the owners chosen market place - that of the developer/purchaser. (The Hudson's Bay Company Ltd v Stevens [1909] 5TC424).
