https://www.taxtmi.com/caselaws?id=272751 Notional profit arising from the annual valuation of stock-in-trade was treated as business income under mercantile principles, because the surplus emerged only when closing stock was valued in the accounts and not from any actual sale at the place where the goods were stored. The legal situs of such profit was held to be the business and accounting process that brought the stock into computation, not the physical location of the stock itself. The argument based on Section 14(2)(c) and related provisions was rejected, and the appreciation in the Bikaner stock was held assessable to tax despite its physical location outside British India. en-us Mon, 04 Jun 1951 00:00:00 +0530 Wed, 16 May 2018 16:09:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=272751 Notional profit arising from the annual valuation of stock-in-trade was treated as business income under mercantile principles, because the surplus emerged only when closing stock was valued in the accounts and not from any actual sale at the place where the goods were stored. The legal situs of such profit was held to be the business and accounting process that brought the stock into computation, not the physical location of the stock itself. The argument based on Section 14(2)(c) and related provisions was rejected, and the appreciation in the Bikaner stock was held assessable to tax despite its physical location outside British India. Case-Laws Income Tax Mon, 04 Jun 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=272751