Returnable bottle deposits are not income where no sale of containers was intended and deposits secured their return.

Deposits received from customers against returnable bottles were not income because the containers were supplied for reuse and the deposits served only to secure their return. No intention to transfer property in the bottles was shown, so the transaction was not a sale and sections 20 to 23 of the Sale of Goods Act did not apply. The deposits were therefore not taxable as the assessee's income.

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Issues: Whether deposits received by the assessee from customers against bottles constituted income of the assessee.

Analysis: The bottles were supplied as returnable containers and the deposits were collected to secure their return for reuse. The transaction was not intended to effect a sale of the bottles, and the deposits were not consideration for the soft drinks or proceeds of sale. In the absence of an intention to transfer property in the bottles, the provisions governing sale under sections 20 to 23 of the Sale of Goods Act had no application to treat the deposit as income.

Conclusion: The deposits were not taxable income of the assessee.

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