162. Sale of asset.

Where under a contract for the sale of land or other property1 there is an agreement to pay a fixed gross sum by annual instalments, the instalments receivable under the contract are instalments of capital and not income2. Where a contract shows on the face of it that the amount of the annual payments is calculated on the capital value of the consideration with interest at an agreed rate, the annual payments, except so far as they consist of interest, are not taxable3, for it is then clear from the contract itself that the capital sum has not been