Section 144C(2) of the Income Tax Act

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.

Interest on outstanding receivables arising during business is considered an international transaction under the definition of 'capital financing'.

Taxation provisions should be interpreted equitably and justly, avoiding hyper-technicality. Courts should view facts naturally, considering circumstances and drawing inferences that promote justice and equity when there are multiple interpretations and no dishonest motive.

The term 'property' in Section 2(14) of the Income Tax Act has the widest amplitude, including any right a person holds in a capital asset. The date of allotment of a property, rather than the date of possession or conveyance deed, is relevant for computing the holding period for capital gains.

A Special Leave Petition filed by the Income Tax Department against a decision concerning the computation of capital gains or related issues was dismissed by the Supreme Court.

A right to a capital asset can exist even without formal ownership through a registered conveyance deed, such as the right derived from an agreement to allot a flat from a builder. This right itself constitutes a capital asset.

The period for which a capital asset is 'held' by an assessee, for the purpose of computing capital gains, is determined by the date when the assessee acquired rights over the asset, not necessarily the date of registration or possession.