https://www.taxtmi.com/caselaws?id=6657 In sales of specific goods, passing of property depends primarily on the parties' intention, and section 20 of the Sale of Goods Act applies only as a presumption where the contract is unconditional and the goods are in a deliverable state. Where the bill of lading and other title documents were delivered in Bombay to representatives of the buyers, the sales were treated as completed in the taxable territories and the entire profit arose there. Where the title documents were sent to Aden and delivered outside the taxable territories, the statutory presumption was displaced by contrary intention, and the sales were not wholly concluded in the taxable territories; profit apportionment was left to the Tribunal. en-us Wed, 23 Feb 1966 00:00:00 +0530 Sat, 31 Jan 2009 16:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6657 In sales of specific goods, passing of property depends primarily on the parties' intention, and section 20 of the Sale of Goods Act applies only as a presumption where the contract is unconditional and the goods are in a deliverable state. Where the bill of lading and other title documents were delivered in Bombay to representatives of the buyers, the sales were treated as completed in the taxable territories and the entire profit arose there. Where the title documents were sent to Aden and delivered outside the taxable territories, the statutory presumption was displaced by contrary intention, and the sales were not wholly concluded in the taxable territories; profit apportionment was left to the Tribunal. Case-Laws Income Tax Wed, 23 Feb 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6657