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2004 (9) TMI 88 - ALLAHABAD HIGH COURTDeduction under section 80P(2)(e) - income of the assessee-co-operative society from a cold storage - "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was correct in holding that the income of the assessee-co-operative society from a cold storage was exempt under the provisions of section 80P(2)(e) of the Income-tax Act, 1961?" - Giving a liberal interpretation of the words "godowns and warehouses" mentioned in section 80P(2)(e) of the Act, a cold storage can be said to be warehouse or godown where goods are stored and thus it falls under the aforesaid section. In this view of the matter, the income from cold storage would be exempt.- In view of the foregoing discussions, we answer the question referred to us in the affirmative, i.e., in favour of the assessee
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