THE COMMISSIONER OF INCOME-TAX, MADHYA PRADESH & BHOPA vs BHOPAL TEXTILES LTD., BHOPAL.

The Supreme Court ruled that under Section 4(1)(a) of the Indian Income-tax Act, 1922, profits from goods supplied by a non-resident company are deemed to be received in British India when payment is made to the agent of the seller. The Court held that the railway receipt acts as a document of title to goods, and property in the goods is transferred upon payment. The decision in Commissioner of Income-tax v. P. M. Rathod & Co. was applied, affirming that the income must be considered received within the taxable territory.