For Section 5(2) of Income Tax Act, income receivable in kind, received at place where goods delivered

Kanchanganga Sea Foods Vs CIT (Supreme Court)- The assessee, a fishing company, obtained two fishing vessels on charter from a foreign company based in Hong-Kong. The charter fee of $ 600,000 was payable from the earning from the sale of fish and for that purpose 85% of the gross earnings from the sale of fish was to be paid to the foreign company. The trawlers were delivered to the assessee at Chennai Port.

Actual fishing operations were done outside the territorial waters of India but with

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