After referring to dicta in the Salisbury House case, [1930] A.C. 432 to the effect that the letting of land does not constitute a "trade", Lord Diplock noted that the word "business" in the Malayan Income Tax Act 1967 was broader (p. 684):
"'Business' is a wider concept than 'trade'; and in the Hanover Agencies case [1967] 1 A.C. 681 the Board uttered a warning against seeking to apply these dicta outside the narrow context of British income tax law and in particular that of Schedule D ... The carrying on of 'business,' no doubt, usually calls for some activity on the part of whoever carries it on, though, depending on the nature of the business, the activity may be intermittent with long intervals of quiescence in between."