https://www.taxtmi.com/caselaws?id=186933 An amount received as earnest money was not income at the time of receipt where the agreement expressly treated it as a refundable or forfeitable contractual deposit rather than part payment of the sale price. The principle that income embedded in sale proceeds is taxable on receipt did not apply, because no part of the gross profit had been received in 1946 and the sum remained a deposit until it was adjusted against the price on completion of the conveyance. The profit was therefore taxable only in assessment year 1951-52 and was not apportionable between assessment years 1946-47 and 1951-52. en-us Tue, 16 Jun 1959 00:00:00 +0530 Tue, 04 Oct 2016 17:26:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186933 An amount received as earnest money was not income at the time of receipt where the agreement expressly treated it as a refundable or forfeitable contractual deposit rather than part payment of the sale price. The principle that income embedded in sale proceeds is taxable on receipt did not apply, because no part of the gross profit had been received in 1946 and the sum remained a deposit until it was adjusted against the price on completion of the conveyance. The profit was therefore taxable only in assessment year 1951-52 and was not apportionable between assessment years 1946-47 and 1951-52. Case-Laws Income Tax Tue, 16 Jun 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186933