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19. Learned counsel for the Revenue relied upon the decision of the Andhra Pradesh High Court in Addl. CIT v. Trustees of H. E. H. the Nizam's Second Supplementary Family Trust [1976] 102 ITR 248. In that case, it was held that the conversion of preference shares into ordinary shares amounted to "transfer" by way of exchange within the meaning of section 45 of the Income-tax Act, and the capital gains that accrued on such conversion were liable to tax. Learned counsel contended that the conversion of foreign currency into Indian rupee will amount to an exchange. There is a fallacy in this argument. An "exchange" is defined by the Transfer of Property Act as a transaction whereby two persons mutually transfer the ownership of one thing for the ownership of another, neither thing or both things being money only. When, admittedly, the ownership of Indian money is obtained in place of ownership of foreign currency, that cannot be considered to be an "exchange" as defined. The contention of learned counsel for the Revenue that it is an "exchange" and, therefore, a "transfer" within the meaning of section 2(47) of the Income-tax Act cannot be accepted.