Section 10(29) exemption denied to a private company leasing godowns, as only a statutory marketing authority qualifies.

Section 10(29) exemption is confined to an authority constituted under a law for marketing commodities, such as a statutory warehousing corporation. A company incorporated under the Companies Act does not qualify as such an authority, and the exemption cannot be extended merely because it derives rental income from godowns used for storage or warehousing. On that reasoning, a private limited company letting a godown to the Food Corporation of India was held not entitled to the deduction, and the issue was answered in favour of the Revenue.

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Issues: Whether a private limited company letting out a godown to the Food Corporation of India was entitled to deduction under section 10(29) of the Income-tax Act, 1961.

Analysis: The benefit of section 10(29) is confined to an authority constituted under any law for the time being in force for the marketing of commodities, such as statutory warehousing corporations. A company incorporated under the Companies Act is not such an authority, and the exemption cannot be extended to a private limited company merely because it earns rental income from godowns used for storage or warehousing purposes.

Conclusion: The assessee was not entitled to deduction under section 10(29); the question was answered in favour of the Revenue and against the assessee.

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