https://www.taxtmi.com/caselaws?id=7204 Sales under c.i.f. contracts for unascertained goods turn on unconditional appropriation under the Sale of Goods Act. Where the seller retains control over the shipping documents and reserves rights if the buyers do not accept or pay against properly submitted documents, or if disputes arise over quality or moisture, property does not pass merely on shipment. On the facts stated, those contractual terms negatived immediate and unconditional transfer of title outside India, so the sales were held not to have taken place outside India and the profits from them were treated as arising within India. en-us Wed, 15 Nov 1967 00:00:00 +0530 Thu, 12 Feb 2009 16:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7204 Sales under c.i.f. contracts for unascertained goods turn on unconditional appropriation under the Sale of Goods Act. Where the seller retains control over the shipping documents and reserves rights if the buyers do not accept or pay against properly submitted documents, or if disputes arise over quality or moisture, property does not pass merely on shipment. On the facts stated, those contractual terms negatived immediate and unconditional transfer of title outside India, so the sales were held not to have taken place outside India and the profits from them were treated as arising within India. Case-Laws Income Tax Wed, 15 Nov 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7204