TaxTMI Login
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →Just a moment...
AI OCR ✕Convert scanned orders, printed notices, PDFs and images into clean, searchable, editable text within seconds. Starting at 2 Credits/page
Try Now →
Press 'Enter' to add multiple search terms. Rules for Better Search
Use comma for multiple locations.
---------------- For section wise search only -----------------
Accuracy Level ~ 90%
of 
Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
of Press 'Enter' after typing page number.
of Press 'Enter' after typing page number.
All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of Press 'Enter' after typing page number.
Issues: Whether a State Warehousing Corporation constituted under the Warehousing Corporations Act, 1962, is an authority constituted for the marketing of commodities and is therefore entitled to exemption under section 10(29) of the Income-tax Act, 1961 in respect of income from letting of godowns and warehouses used for storage, processing or facilitating the marketing of commodities.
Analysis: The exemption under section 10(29) applies where the assessee is an authority constituted under law for the marketing of commodities and the exempt income is derived from letting of godowns or warehouses for storage, processing or facilitating marketing. The statutory scheme of the Warehousing Corporations Act, 1962 shows that a State Warehousing Corporation is created for warehousing agricultural produce and notified commodities, with functions extending to acquiring and running warehouses, arranging transport, and acting as agent for purchase, sale, storage and distribution. The expression "for the marketing of commodities" was construed in its wider, beneficial sense, because warehousing, storage and transport are essential parts of the marketing process and enhance the utility and value of commodities. The Court also noted the legislative history and the analogous exemption in earlier income-tax provisions, reinforcing that Parliament intended such statutory warehousing bodies to receive the exemption.
Conclusion: The Corporation is an authority for marketing commodities and satisfies the conditions of section 10(29); the exemption is allowable in favour of the assessee.
Ratio Decidendi: A statutory warehousing corporation whose mandated functions include warehousing, storage, transport, and agency for purchase, sale and distribution is an authority constituted for the marketing of commodities, because those activities form an essential part of the marketing process for purposes of section 10(29).
TaxTMI 
TaxTMI 
