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4.1 Our first observation in the matter is that there is no basis for the ld. CIT(A) to hold that the services rendered by the real estate broker, M/s. Hanu Reddy Realty India Pvt. Ltd., were in respect of transfer of shares. Why would, one may ask, anyone be interested in purchasing shares in a private limited company (transferability of which is severely limited by law), without any business or business proposal, and without any tangible or intangible asset, save the plot of land, which is in fact a common plot (# 7A of Dyavasandra Phase I, Industrial Area), with each company ITA Nos. 1756 & 1757/Mum/2012 (A.Y. 2007-08) holding a part thereof, except where he intends to acquire the land or interest therein. The broker is a real estate broker and the buyer was interested in acquiring land. It is only for this reason that the services of a real estate broker were required. There is in fact not even a contention denying this, with the assessee himself stating that though technically a case of sale of shares, in the real sense of the word (read 'world'), it is immovable property that was the subject matter of transfer, i.e., in substance. Clearly, the buyer, who may have been located by the broker, even negotiating the price of land or participating in the process, bought the shares only to acquire the interest in land through the medium of the company. The ld. CIT(A) misdirects himself when he holds otherwise. We are conscious that the Revenue is not in appeal, and the issue of deductibility of brokerage expenses is therefore not open. However, this aspect, i.e., the substance of the transaction, and for which therefore the services of the broker and the solicitor were required, is common (to the deductions claimed u/s. 48(i)), so that to the extent the impugned order is inconsistent with our order, its' merger with the latter would operate to override the same.