https://www.taxtmi.com/caselaws?id=277293 Profits from sales of unascertained goods to European and American buyers accrued outside British India because property passed only when the goods were ascertained and unconditionally appropriated, and the seller retained control through the bill of lading until the bill of exchange was accepted in London. The Madras bank's advance was only a loan on the security of the shipping documents, not payment of the sale price, so it did not constitute receipt in British India. The actual sale proceeds were realised through the London bank, and the later adjustment of the Madras advance merely reduced the assessee's liability. On these facts, the income neither arose nor was received in British India. en-us Thu, 29 Mar 1951 00:00:00 +0530 Fri, 30 Nov 2018 15:21:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277293 Profits from sales of unascertained goods to European and American buyers accrued outside British India because property passed only when the goods were ascertained and unconditionally appropriated, and the seller retained control through the bill of lading until the bill of exchange was accepted in London. The Madras bank's advance was only a loan on the security of the shipping documents, not payment of the sale price, so it did not constitute receipt in British India. The actual sale proceeds were realised through the London bank, and the later adjustment of the Madras advance merely reduced the assessee's liability. On these facts, the income neither arose nor was received in British India. Case-Laws Income Tax Thu, 29 Mar 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277293