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Case lawSupreme Court › CIT v Bai Shirinbai K Kooka
Supreme CourtHelps taxpayers.28s.45(2)s.2(14)

CIT v Bai Shirinbai K Kooka

I held shares as an investment for years and then started dealing in them. When I sell, is my profit measured from what I originally paid or from the market value on the day I began trading?

I held shares as an investment for years and then started dealing in them. When I sell, is my profit measured from what I originally paid or from the market value on the day I began trading?

From the market value on the day the trading began. A seven-judge bench of the Supreme Court held, by six to one, that where an investor converts shares into stock-in-trade and then sells them in the course of business, the profits must be computed on ordinary commercial principles: the difference between what the article cost the business and what it fetched on sale. What the shares cost this business was their market value on 1 April 1945, the day the trading activity started. There is no notional sale involved; the sale that produced the profit was a real one, and the only question was how to measure it.

Decided by the Supreme Court (Supreme Court of India, seven judges; S.K. Das, J.L. Kapur, P.B. Gajendragadkar, A.K. Sarkar, K. Subba Rao, K.N. Wanchoo and N. Rajagopala Ayyangar JJ. Majority judgment by S.K. Das J; Sarkar J dissenting) on 1962-02-23, reported as 1963 AIR 477; 1962 SCR Supl. (3) 391; AIR 1963 SUPREME COURT 477. It bears on section 28, section 45(2), section 2(14) of the Income Tax Act 1961, in Assessment & Scrutiny and Capital Gains matters.

Still good law. A seven-judge decision which the source page records as cited in more than one hundred later cases, with the Supreme Court itself explaining, distinguishing or following it repeatedly between 1963 and 1992. It construes section 10 of the 1922 Act, whose successor is section 28 of the 1961 Act. The batch line identifies section 45(2) of the 1961 Act, on conversion of a capital asset into stock-in-trade, as the modern provision; that section was not read in this session, so how far it displaces the computation adopted here has not been verified and should be checked before the case is relied on for a conversion after its introduction.

Why it matters

This is the leading decision on the dividing line between an asset held on capital account and the same asset once it enters a trade, and it supplies the measure of business profit in conversion cases. It is also the case that confined Kikabhai Premchand. The Court held Kikabhai decides only that the State cannot tax a profit that a person might have made but chose not to make, and that each year is a self-contained accounting period; it does not decide how actual profits from an actual sale are to be computed. That distinction is why both cases survive and why practitioners must identify which side of the line their facts fall on. The Court also placed Sharkey v Wernher in its proper position, as an authority of persuasive value only and not binding, and declined to reconsider Kikabhai because the facts did not require it. Sarkar J dissented, holding that the cost is what the assessee actually paid and that the majority's approach amounts to a fictional sale to oneself.

Binding on every court and authority in India.

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