https://www.taxtmi.com/caselaws?id=5023 Income from mining sales accrues where the seller acquires an enforceable right to receive the sale price, which in a sale of goods depends on where property passes. On the stated facts, the seller retained control of the railway receipts, consigned the goods to self, and the purchasers received delivery only after paying the bank, so the seller reserved the right of disposal and title did not pass at Bhilwara. The bank's role did not make it the purchaser's agent or amount to receipt of price in the Part B State. The rebate under the Part B States (Taxation Concessions) Order, 1950 was therefore not available, and apportionment based on manufacturing activity was not entertained. en-us Fri, 05 May 1967 00:00:00 +0530 Tue, 18 Nov 2008 16:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5023 Income from mining sales accrues where the seller acquires an enforceable right to receive the sale price, which in a sale of goods depends on where property passes. On the stated facts, the seller retained control of the railway receipts, consigned the goods to self, and the purchasers received delivery only after paying the bank, so the seller reserved the right of disposal and title did not pass at Bhilwara. The bank's role did not make it the purchaser's agent or amount to receipt of price in the Part B State. The rebate under the Part B States (Taxation Concessions) Order, 1950 was therefore not available, and apportionment based on manufacturing activity was not entertained. Case-Laws Income Tax Fri, 05 May 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5023