https://www.taxtmi.com/caselaws?id=273718 Trading profits from speculative forward contracts accrue or arise for income-tax purposes on the cumulative effect of the relevant facts, not by reference to the place of contract alone. The place of conclusion, performance of acts under the contract, and the place where the right to receive payment arises are all relevant, but no single test is decisive in foreign-transaction cases. On the facts stated, the contracts were concluded at Sangli, no delivery was contemplated, and the profits arose from market differences there, so the profits did not accrue or arise in British India. Because the sums were not chargeable as income in the non-residents' hands, the resident buyers had no duty to deduct tax at source. en-us Wed, 12 Jan 1955 00:00:00 +0530 Wed, 11 Jul 2018 11:18:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273718 Trading profits from speculative forward contracts accrue or arise for income-tax purposes on the cumulative effect of the relevant facts, not by reference to the place of contract alone. The place of conclusion, performance of acts under the contract, and the place where the right to receive payment arises are all relevant, but no single test is decisive in foreign-transaction cases. On the facts stated, the contracts were concluded at Sangli, no delivery was contemplated, and the profits arose from market differences there, so the profits did not accrue or arise in British India. Because the sums were not chargeable as income in the non-residents' hands, the resident buyers had no duty to deduct tax at source. Case-Laws Income Tax Wed, 12 Jan 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273718