Gujarat vs. Ramanlal S & Co.
When on dissolution of the firm ramanlal s & co. , the assets of firm were divided among the partners, the sales tax officer assessed the firm to sales tax on the ground that goods were allotted to partners and therefore liable to be taxed as if they were sold to the partners.
It was held that it was not a sale. The partners being the joint owners of those assets cannot be both buyer and seller.
Two parties to a contract is an essential to a valid contract.