COMMISSIONER OF INCOME-TAX, DELHI vs MESSRS. P. M. RATHOD & CO.

The Supreme Court held that the income from sales of goods sent by Value Payable Post or by rail should be assessed based on the place of receipt. It was determined that the payment received from a buyer by a banker in Part A or C States against delivery of railway receipts does not constitute a receipt in those States but rather in Ratlam, a Part B State. The Court reframed the questions posed by the High Court and upheld the Tribunal's decision that the respondents were liable to be assessed at concessional rates applicable to Part B States under the Income Tax Act.