https://www.taxtmi.com/caselaws?id=6358 In a c.i.f. sale financed by an irrevocable letter of credit, property in unascertained goods passes when the seller unconditionally appropriates the goods to the contract by shipping them and tendering the bill of lading and related documents against payment, without reserving the right of disposal. Rights allowing the buyer to reject for non-conformity or to claim for quality or moisture defects do not, by themselves, postpone transfer of title, because they do not make inspection or acceptance a condition precedent to passing of property. On that basis, the sales were treated as having taken place outside India, and the profits were treated as arising outside India. en-us Fri, 08 Sep 1972 00:00:00 +0530 Thu, 15 Jan 2026 12:38:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6358 In a c.i.f. sale financed by an irrevocable letter of credit, property in unascertained goods passes when the seller unconditionally appropriates the goods to the contract by shipping them and tendering the bill of lading and related documents against payment, without reserving the right of disposal. Rights allowing the buyer to reject for non-conformity or to claim for quality or moisture defects do not, by themselves, postpone transfer of title, because they do not make inspection or acceptance a condition precedent to passing of property. On that basis, the sales were treated as having taken place outside India, and the profits were treated as arising outside India. Case-Laws Income Tax Fri, 08 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6358