Sir Kikabhai Premchand vs Commissioner Of Income Tax ... on 9 October, 1953
In Kikabhai's case Sir Kikabhai wanted to make a trust in which not only he himself was interested but also his wife and children. In the case before us the two entities are entirely identical, and, to use the language of the Supreme Court, it is entirely unreal and artificial to treat these two identical entities as doing business with each other and by means a fictional sale producing a fair profit which the Income-tax department seeks to tax.