1954 (3) TMI 43

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....s Rs. 1,99,179-3-4, which represents the price of coffee seeds, which the assessee exported outside the Indian territory during the assessment year. The contract for the sale with the foreign buyers was on the 26th October, 1949, and the coffee seeds were booked on the 25th January, 1950, at Mangalore. The ship actually left the port on the 28th January, 1950. The foreign purchasers opened a lette....

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....ted. Viewing the question apart from the Constitution we are clearly of opinion that the property in the goods passed to the buyer outside the Indian territory and only when the bill of exchange was accepted by the buyer and the bill of lading was handed over to the buyer or his bank. A similar question was considered under the Income-tax Act by this Court in Commissioner of Income-tax, Madras v.....