Sir Kikabhai Premchand v. CIT

116 ITR 425High Court1979#4427 most cited

What is Sir Kikabhai Premchand v. CIT authority for?

A person cannot enter into a contract with themselves, meaning no profit or loss can arise from self-dealing. This principle applies to the computation of profits under domestic income tax law but does not necessarily extend to profit attribution under tax treaties for permanent establishments.

27

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

Sir Kikabhai Premchand v. CIT · Betts Hartley Huett and Co. Ltd. vs. CIT · profit from oneself · no contract with oneself · domestic law · tax treaty · permanent establishment · Article 7 · DTAA

Sections most often in play

Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(2)Section 144C(5)Section 234BSection 234C

Issues it is cited on

tax treatypermanent establishmentdispute resolution panelnon-residentdraft assessment ordersection 143prescribedpersoncompanysection 14section 143(3)india

Judgments citing Sir Kikabhai Premchand v. CIT

M/S. TBEA SHENYANG TRASFORMER GROUP COMPANY LIMITED,,VADODARA vs. THE DEPUTY COMMISSIONER OF INCOME TAX, INT. TAX.,, VADODARA

Appeal is dismissed

ITA 121/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2013-14

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2013-2014 M/S.Tbea Shenyang Transformer Dcit, International Group Company Limited Vs. Taxation Tbea Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara Pan : Aadct 4557 F (Applicant) (Responent) : Assessee By Ms.Amrin Pathan, Ar : Shri Mahesh Shah, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 29/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025 आदेश आदेश/O R D E R आदेश आदेश Per Makarand V.Mahadeokar, Am: This Appeal By The Assessee Arises From The Assessment Order Dated 07.11.2017 Passed By The Deputy Commissioner Of Income Tax, International Taxation, Vadodara [Hereinafter Referred To As “Assessing Officer Or Ao”], Under Section 143(3) Read With Section 144C(13) Of The Income Tax Act, 1961 For Assessment Year 2013-14 In Accordance With The Directions Of The Dispute Resolution Panel – 2, Mumbai [Hereinafter Referred To As “Drp”]

Section 142(1)Section 143(2)Section 143(3)Section 144C(13)Section 144C(2)Section 144C(5)Section 271(1)(c)Section 92BSection 92CSection 92E

…आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण,अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ ‘D’ अहमदाबाद। अहमदाबाद "यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, AHMEDABAD ]BEFORE S/SHRI SANJAY GARG, JUDICIAL MEMBER AND MAKARAND V.MAHADEOKAR, ACCOUNTANT MEMBER Asstt.Year : 2013-2014 M/s.TBEA Shenyang Transformer DCIT, International Group Company Limited Vs. Taxation TBEA Green Energy Park Vadodara. National Highway No.8 Village : Miyagam Karjan Vadodara PAN : AADCT 4557 F (Applicant) (Responent) : Assessee by Ms.Amrin Pathan, AR : Shri Mah…

DCIT, CIRCLE-1(2)(1) (INTERNATIONAL TAXATION), NEW DELHI vs. COBRA INSTALACIONES Y SERVICIOS S.A., NEW DELHI

In the result, the appeal filed by the Revenue stands dismissed

ITA 7173/DEL/2019[2016-17]Status: DisposedITAT Delhi12 Jul 2022AY 2016-17
For Appellant: Shri Hiren Mehta, CAFor Respondent: Shri Sanjay Kumar, Senior DR

…om head office and any claim that this amount is loan from head office to project office is only an afterthought. 7. Further, the AO placed reliance on the judgment of the Hon'ble Calcutta High Court in the case of Betts Hartley Huett and Co. Ltd. vs. CIT, 116 ITR 425 wherein it is held that (a) it is an elementary proposition that no person can enter into a contract with oneself (b) Debiting or crediting one's account cannot alter this legal position and (c) no question of profit or loss can arise as no person can enter into a contract with oneself. 5 ITA No.7173/Del./2019 8. Furthermore, the AO made refe…

SHINHAN BANK,MUMBAI vs. DDIT (IT) RG 2(1), MUMBAI

In the result, the appeal is partly allowed in the terms indicated above

ITA 6994/MUM/2012[2008-09]Status: DisposedITAT Mumbai27 Jun 2022AY 2008-09
Section 143(3)Section 44C

…ny payments and incomes, whatever be its relevance or irrelevance in the cross-border situations, finds its support from judicial precedents in the cases of Sir Kikabhai Premchand Vs CIT [(1953) 24 ITR 506 (SC)] and Betts Hartley Huett & Co Ltd Vs CIT [(1979) 116 ITR 425 (Cal)], is in the context of the computation of profits under the Income Tax Act. This theory would not, therefore, extend to the computation of profits attributable to a permanent establishment under the scheme of the tax treaties. The five- member bench decision, in the case of Sumitomo Mitsui Banking Corp (supra) recognizes this position and s…

SHINHAN BANK,MUMBAI vs. DDIT (IT) RG 2(1), MUMBAI

In the result, the appeal is partly allowed in the terms indicated above

ITA 6993/MUM/2012[2007-08]Status: DisposedITAT Mumbai27 Jun 2022AY 2007-08
Section 143(3)Section 90

…ds its support from judicial precedents in the cases of Sir Kikabhai Premchand Vs CIT [(1953) 24 ITR 506 (SC)] and Betts CO Nos.: 113/Mum/2016 and 36/Mum/ 2020 ITA No. 6993/Mum/2012; Assessment year 2007-08 Page 21 of 29 Hartley Huett & Co Ltd Vs CIT [(1979) 116 ITR 425 (Cal)], is in the context of the computation of profits under the Income Tax Act. This theory would not, therefore, extend to the computation of profits attributable to a permanent establishment under the scheme of the tax treaties. The five-member bench decision, in the case of Sumitomo Mitsui Banking Corp (supra) recognizes this position and sp…

M/S KEMFIN SERVICES PVT LTD vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

In the result, the appeal is allowed

ITA/70/2011HC Karnataka11 Jun 2020

Bench: ALOK ARADHE,HEMANT CHANDANGOUDAR

Section 143(2)Section 260Section 260ASection 88E

…f transfer and not at any other point of time and therefore, the cost on the date of actual acquisition must be taken as cost of acquisition. In support of aforesaid submissions, reliance has been placed on decisions in ‘CIT VS. DHANUKA & SONS’, (1980) 124 ITR 24 (CAL), ‘SIR KIKABHAI PREMCHAND VS. CIT’, (1953) 24 ITR 506 (SC), ‘KEMFIN SERVICES PVT. LTD. VS. ACIT’, ITA NOS.1450 & 1451(B)/2015, ‘CIT VS. BANGALORE DEVELOPERS PVT. LTD.,’, (2017) 392 ITR 379 (KAR), ‘PR.CIT VS. PAVITRA COMMERCIAL 9 LTD.’, (2018) 402 ITR 66 (DEL), ‘CIT VS. YATISH TRADING CO. PVT LTD.,’, 2013-TIOL-117-HC-MUM-…

ACIT, NEW DELHI vs. M/S MODLAND WEARS PVT. LTD., NEW DELHI

In the result, the Ground Nos

ITA 3587/DEL/2011[2008-09]Status: DisposedITAT Delhi28 Jan 2020AY 2008-09

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2008-09

Section 143(3)Section 14A

…ris [1904] 5 TC 159(C. Exchq.) (iv) Raja Mohan Raja Bahadur Vs. CIT [1967] 66 ITR 378; (v) British South Africa Co. Vs. Varty (Inspector of Taxes) [1966] AC 381; (vi) Sir Kikabhai Premchand Vs. CIT, (1953) 24 ITR 506 (SC) (vii) CIT Vs. Dhanuka & Sons, (1980), 124 ITR 24(Cal.) (viii) ACIT Vs. Bright Star Investment (P) Ltd. (ITAT-Mum.) (ix) CIT Vs. Bai Shirinbai K. Kooka 5.6 In view of the ratio of the judgments, the Ld. CIT(A) deleted the addition of ₹ 14,19,57,154 observing as under: “5.9 Thus, it may be seen that the view taken by the Hon’ble courts in the aforementioned cases is that to bring to tax any busi…

M/S. PRATHAM DEVELOPERS,,VADODARA vs. THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2),, BARODA

In the result, Ground No.4 of the assessee’s appeal is allowed in part

ITA 3087/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad29 Jan 2019AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr आयकर अपील सं./I.T.A. Nos. 742/Ahd/2015, 3078 & 3077/Ahd/2016 With Cross Objection No. 76/Ahd/2015 & 9/Ahd/2017 & I.T.A. No. 3087/Ahd/2016 (In I.T.A. Nos. 742/Ahd/2015, 3078 & 3077/Ahd/2016) & ("नधा"रण वष" / Assessment Years : 2010-11, 2012-13 & 2013-14)

For Respondent: Shri Mudit Nagpal, Sr. D.R

…l income can be taxed. 14. With respect to the contention of the AO that classification from stock to investments cannot be made, we respectfully submit that the income tax law is not alien to such classifications. In the case of CIT v. Dhanuka & Sons [1980] 124 ITR 24 (Cal) the High Court has recognized such principle and it was held that loss arising on such classification cannot be allowed. ''Business Loss - Transfer of shares from trading account to investment account Transaction is not in course of business with third party - No sale involved in transaction as a person cannot sell to himself and make profi…

THE DCIT, CIRCLE-1(2),, BARODA vs. M/S. PRATHAM INVESTMENTS,, BARODA

ITA 742/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad29 Jan 2019AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad, Judicial Memebr आयकर अपील सं./I.T.A. Nos. 742/Ahd/2015, 3078 & 3077/Ahd/2016 With Cross Objection No. 76/Ahd/2015 & 9/Ahd/2017 & I.T.A. No. 3087/Ahd/2016 (In I.T.A. Nos. 742/Ahd/2015, 3078 & 3077/Ahd/2016) & ("नधा"रण वष" / Assessment Years : 2010-11, 2012-13 & 2013-14)

For Respondent: Shri Mudit Nagpal, Sr. D.R

…l income can be taxed. 14. With respect to the contention of the AO that classification from stock to investments cannot be made, we respectfully submit that the income tax law is not alien to such classifications. In the case of CIT v. Dhanuka & Sons [1980] 124 ITR 24 (Cal) the High Court has recognized such principle and it was held that loss arising on such classification cannot be allowed. ''Business Loss - Transfer of shares from trading account to investment account Transaction is not in course of business with third party - No sale involved in transaction as a person cannot sell to himself and make profi…

M/S. PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL.CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 2469/DEL/2014[2010-11]Status: DisposedITAT Delhi09 Jan 2019AY 2010-11

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

DCIT, NEW DELHI vs. M/S. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 2966/DEL/2013[2009-10]Status: DisposedITAT Delhi09 Jan 2019AY 2009-10

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 2406/DEL/2013[2009-10]Status: DisposedITAT Delhi09 Jan 2019AY 2009-10

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 4722/DEL/2012[2008-09]Status: DisposedITAT Delhi09 Jan 2019AY 2008-09

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

ACIT, NEW DELHI vs. M/S. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 4718/DEL/2012[2008-09]Status: DisposedITAT Delhi09 Jan 2019AY 2008-09

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

PUNJAB NATIONAL BANK,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 1788/DEL/2012[2006-07]Status: DisposedITAT Delhi09 Jan 2019AY 2006-07

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

PUNJAB NATIONAL BANK,NEW DELHI vs. ACIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 4253/DEL/2011[2006-07]Status: DisposedITAT Delhi09 Jan 2019AY 2006-07

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

ACIT, NEW DELHI vs. PUNJAB NATIONAL BANK, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 2469/DEL/2011[2007-08]Status: DisposedITAT Delhi09 Jan 2019AY 2007-08

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

PUNJAB NATIONAL BANK,NEW DELHI vs. ACIT, NEW DELHI

In the result, assessee’s appeals, namely, ITA Nos

ITA 2236/DEL/2011[2007-08]Status: DisposedITAT Delhi09 Jan 2019AY 2007-08

Bench: Shri Prashant Maharishi & Shri K.Narasimha Chary

For Appellant: S/Shri K. Sampath & V. Raja Kumar, AdvocateFor Respondent: Smt. Sulekha Verma, CIT,DR
Section 14Section 14A

…ferring as though from one pocket to the other pocket when it had operated the inter branch accounts of this nature. In our view, the decision of the Hon'ble Apex Court in the case of Sir Kikabhai Premchand Vs. CIT - 24 ITR 506 and Hon'ble Calcutta Vs. CIT - 116 ITR 425 are clearly in favour of the assessee. The accounting entries, which according to the Revenue, yield the income are in the inter branch accounts of the bank. It cannot be said that transactions between the branch can result in an income to the bank as a whole. No man can make profit to himself by the transactions with the self. Each branch of the…

ASST. CIT, CIRCLE-6, PUNE vs. SAKAL PAPERS LIMITED,, PUNE

In the result, appeal of the Revenue in ITA No

ITA 926/PUN/2013[2006-07]Status: DisposedITAT Pune20 Dec 2018AY 2006-07

Bench: Shri R.S. Syal, Vp & Shri Partha Sarathi Chaudhury, Jm

For Appellant: Shri Ashok KotharyFor Respondent: Shri Sudhendu Das
Section 80I

…nal relied upon the decision of the Supreme Court in the case of Sir Kikabhai Premchand vs. CIT 24 ITR 506, for the proposition that no man can make a profit out of himself and on the decision of the Calcutta High Court in the case of CIT vs. Dhanuka and Sons 124 ITR 24, where the High Court held that there could not be any actual profit or loss on withdrawal of stock from a trading business. It is clear from this decision of the Supreme Court that conversion of stock-in- trade into capital asset and vice-versa is permissible and the assessee can decide as per his requirement what should constitute stock-in-trade…

COBRA INSTALACIONES Y SERVICIOS SA,NEW DELHI vs. DCIT, CIRCLE- 1(1)(1), INTL. TAXATION, NEW DELHI

In the result, appeal of the assessee is allowed

ITA 2391/DEL/2018[2014-15]Status: DisposedITAT Delhi28 Jun 2018AY 2014-15

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri Hiren Mehta, C.A. and Shri Nirbhay Mehta, AdvocateFor Respondent: Shri Satpal Gulati, CIT-D.R

…been shown as loan from Head Office and any claim that this amount is loan from Head Office to Project Office is only an afterthought. The A.O. relied upon the decision of Hon'ble Calcutta High Court in the case of Betts Hartley Huett and Co. Ltd. vs. CIT, 116 ITR 425 in which it was held that “no question of profit or loss can arise as no person can enter into a contract with oneself”. If a Company has opened a Project Office in India with the purpose of doing business, it will have to remit/invest some amount of money for the functioning of the business. Such money cannot be called as loan given to the Proj…

ACIT, CIR-36, KOLKATA, KOLKATA vs. SRI KAMAL KUMAR DUGAR, KOLKATA

In the result, the appeal of the revenue is dismissed

ITA 1823/KOL/2014[2010-2011]Status: DisposedITAT Kolkata07 Jul 2017AY 2010-2011

Bench: Hon’Ble Sri A.T.Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No.1823/Kol/2014 Assessment Year : 2010-11 A.C.I.T., Circle-35, -Vs.- Shri Kamal Kumar Dugar Kolkata Kolkata [Pan : Adepd 5604 J] (Respondent) (Appellant) For The Appellant : None For The Respondent : Shri Anil Kochar, Advocate Date Of Hearing : 15.06.2017. Date Of Pronouncement : 07.07.2017 Order

For Appellant: NoneFor Respondent: Shri Anil Kochar, Advocate
Section 143(3)

…biting the conversion of shares from Trading Account to Investment 5 6 Shri Kamal Kumar Dugar A.Yr.2010-11 Account. The assessee also placed reliance on the decision of the Hon’ble Calcutta High Court in the case of CIT vs Dhanuka and Sons reported in [1979] 124 ITR 24 (Cal) dated 21.7.1978, it had been categorically held that profit and gains on shares transferred from trading account to investment at prevailing market rate is not a transaction at all because a person cannot have transaction with himself and in turn such profit cannot be taxed. If such shares be disposed of at a value other than the value at wh…

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Sir Kikabhai Premchand v. CIT (116 ITR 425) — Cited in 27 Judgments | BharatTax