The Excess Profits Tax is applicable in any case where the selling or leasing of land constitutes a trade or business. Individuals are not, however, within the application of the special provision contained in Sub-section (4) of Section 12 of the Finance (No. 2) Act, 1939, which provides that, where the function or main function of an incorporated company or society is to hold property, the holding of property is in itself to be deemed to be a business.