https://www.taxtmi.com/caselaws?id=6411 Transfers of pucca delivery orders in gunny bag transactions were examined for whether they amounted to speculative transactions under Explanation 2 to the proviso to section 24(1) of the Indian Income-tax Act, 1922. The controlling question was not whether the assessee physically delivered the goods to its immediate transferee, but whether the last holder of the delivery orders ultimately obtained actual delivery of the goods. The Court treated delivery orders as documents of title and held that intermediate transfers may not be decisive where title and delivery are completed through the chain. On the material before it, the transactions could not be finally characterised as speculative, and further factual enquiry was required. en-us Wed, 25 Apr 1973 00:00:00 +0530 Thu, 04 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6411 Transfers of pucca delivery orders in gunny bag transactions were examined for whether they amounted to speculative transactions under Explanation 2 to the proviso to section 24(1) of the Indian Income-tax Act, 1922. The controlling question was not whether the assessee physically delivered the goods to its immediate transferee, but whether the last holder of the delivery orders ultimately obtained actual delivery of the goods. The Court treated delivery orders as documents of title and held that intermediate transfers may not be decisive where title and delivery are completed through the chain. On the material before it, the transactions could not be finally characterised as speculative, and further factual enquiry was required. Case-Laws Income Tax Wed, 25 Apr 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6411