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1960 (8) TMI 3 - SC - Income TaxWhether the profits of the Panrope Corporation and the non-resident company in respect of the consignment goods were received in the taxable territories on their behalf ? Held that:- Unable to agree with the reasoning and the conclusion of the High Court. The terms of the agreement make it abundantly clear that the goods " received on consignment " from the foreign corporations were received by the S. K. F. as their selling agent and not as purchaser. The goods, it is true, were sold by the S. K. F. in its own name and not in the name of the foreign corporations, but the goods were still sold for and on behalf of the foreign corporations and the sale proceeds received by the S.K.F. were received not on its own behalf but for and on behalf of its principals. In the view taken by us, the question will be answered in the affirmative in respect of sale of all goods where the price has been received by the S. K. F. in the taxable territories, and irrespective of whether the remittance has been made in respect of the goods sold before or after the price was received. Appeal allowed in part
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