Tax exemption for godowns and warehouses is limited to letting income, not separate income from processing or marketing facilitation.

The exemption under section 14(3)(iv) of the Income-tax Act, 1922 and section 81(iv) of the Income-tax Act, 1961 is confined to income derived from letting of godowns or warehouses, where the letting is for storage, processing, or facilitating the marketing of commodities. The words "storage, processing or facilitating the marketing of commodities" describe the permitted purposes of letting and do not create separate, independent exemption heads for income from processing or marketing facilitation itself. The construction was supported by the corresponding language in section 83 and the legislative history of the provision, which showed that "processing" would otherwise be redundant.

---

---

Issues: Whether the exemption under section 14(3)(iv) of the Income-tax Act, 1922 and section 81(iv) of the Income-tax Act, 1961 extends to income from processing and from facilitating the marketing of commodities, or is confined to income derived from letting of godowns or warehouses for the purposes of storage, processing, or facilitating the marketing of commodities.

Analysis: The language of both provisions was held to be plain and grammatical, and the words "storage, processing or facilitating the marketing of commodities" were construed as the purposes for which godowns or warehouses must be let. The exemption was treated as a single composite one, dependent on income being derived from letting of godowns or warehouses, rather than as three independent exemptions for storage, processing, and marketing activity. Support for this construction was drawn from section 83, which uses the same language, and from the legislative history of the corresponding provision introduced by section 10 of the Finance Act, 1955, showing that the word "processing" would otherwise become redundant.

Conclusion: The exemption is confined to income derived from letting of godowns or warehouses where the letting is for storage, processing, or facilitating the marketing of commodities, and does not extend as a separate exemption to income from processing or from facilitating the marketing of commodities.

Ratio Decidendi: Where a tax exemption provision links income from letting of godowns or warehouses to specified purposes, the specified words denote the purposes of letting and do not create independent heads of exemption for the activities named.

---