TMI Blog1989 (1) TMI 3X X X X Extracts X X X X X X X X Extracts X X X X ..... onstruction of the agreement between the assessee and the State Government, the Tribunal's finding that the receipts were mostly for letting out the godowns and that the servicing was an insignificant portion of the whole amount is reasonable - - - - - Dated:- 25-1-1989 - RANGANATH MISRA. and R. S. PATHAK. JUDGMENT The judgment of the court was delivered by PATHAK C. J. I .-This appea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... stock at the rail-head and transporting it to the godowns. During the previous year relevant to the assessment year 1961-62, the assessee received a sum of Rs. 31,316 on this account, the amount being described as commission. In the assessment proceedings for the assessment year 1961-62, the assessee claimed exemption from tax under section 14(3)(iv) of the Indian Income-tax Act, 1922, in respe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ved by the assessee-society from the Madras Government under an agreement for stocking and distribution of ammonium sulphate was exempt under section 14(3)(iv) of the Indian Incometax Act, 1922 ? 2. Whether, on the construction of the agreement between the assessee and the State Government, the Appellate Tribunal's finding that the receipts were mostly for letting out the godowns and that the se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the development of rural economy, and exemption was granted from income-tax in respect of income derived from the letting of such warehouses for the storage, of fertilisers and other related commodities concerned with co-operative marketing. Having regard to the object with which the provision has been enacted, it is apparent that a liberal construction should be given to the language of the prov ..... X X X X Extracts X X X X X X X X Extracts X X X X
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