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2012 (6) TMI 678 - HC - Income TaxDeduction under section 80P(2)(e) of the Act - godown on rent - let out to the FCI or any other agency for the purposes of storage - co-operative society – Held that:- assessee was purchasing the goods and then selling the goods to the FCI and in such a situation, storing was part of business of the assessee and did not amount to letting out of storage capacity as till the goods were sold to the FCI, goods belonged to the assessee itself, and not to the FCI – income not entitled to special deduction Deduction under section 80G - income of the assessee is partly exempt and partly liable to tax – Held that:- Tribunal in the assessee’s own case (supra) direct the Assessing Officer to allow deduction under section 80G out of the taxable income of the assessee - It is not clear in the order of the Tribunal that the assessee had produced any proof – matter remanded to Tribunal for want of proof. Expenditure for construction of Sahakarita Bhawan and amount paid to Co-operative Development Federation for modernizing the printing press - construction was done on the direction of the State Government – Held that:- claim of the assessee was not controverted by the revenue - expenditure was revenue in nature was clearly distinguishable as therein tenements constructed for welfare of employees did not vest in the asses- see and the assessee did not get any benefit of enduring nature - matter remanded to the Tribunal
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