Cross v. London Provincial Trust Ltd., [1938] 1 All E.R. 428 (C.A.) -- summary under Payment & Receipt

The taxpayer, who held bonds on which the payment of interest had been suspended, exchanged his matured interest coupons on the bond for interest-bearing 20-year funding bonds of the debtor. In finding that the funding bonds did not constitute "income arising from securities outside the United Kingdom", MacKinnon L.J. stated (at p. 435) that "there can never be payment of its debt by a debtor by giving his own promise to pay at a future date ... though income arises to a creditor from a debtor's paying his debt, income does not arise by the debtor's promising that he will pay his debt later on".