PUSHALAL MANSINGHKA (P) LTD. vs COMMISSIONER OF INCOME-TAX, DELHI,RAJASTHAN & M.P.

The Supreme Court held that under Section 4(1)(a) of the Income-tax Act, 1922, the appellant's income from sales of mica to purchasers in Part 'A' and Part 'C' States accrued in those States, not in the Part 'B' State where the appellant operated. The Court clarified that property in goods does not pass until the purchaser pays the price and receives the railway receipt, thus denying the appellant's claim for tax exemption under the Part 'B' States (Taxation Concessions) Order, 1950. The appeal was dismissed, affirming the lower courts' decisions.