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<h1>Cooling Charges to Cold Storage Not Subject to Section 194-I; Section 194-C Applies Due to Contractual Nature.</h1> The circular addresses the applicability of Section 194-I to cooling charges paid by customers to cold storage owners. It clarifies that these charges are not subject to Section 194-I as customers do not hire or become tenants of the cold storage facilities. The primary function of the cold storage is preservation through mechanical processes, with storage being incidental. Consequently, Section 194-I is not applicable. However, since the arrangement is contractual, Section 194-C applies to the cooling charges. This information should be communicated to the relevant Assessing Officers.