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Disallowance of deduction u/s 80P in respect of storage income derived from CAP storage - There is no specific definition of “godown” and “warehouse” prescribed in Income-tax Act, 1961. - At this stage, we also note that the section 80P is a beneficial provision and the purpose is to incentivize the warehousing activity of co-operative societies. Therefore, the interpretation of section 80P must be liberal so as to advance the avowed objective. Taking into account all these aspects, we are persuaded to conclude that the income from letting of CAP storage derived by the assessee is eligible for deduction u/s 80P and there is no justification in denying the same to the assessee. Therefore, we delete the disallowance made by lower authorities. - AT
Disallowance of deduction u/s 80P in respect of storage income derived from CAP storage - There is no specific definition of “godown” and “warehouse” prescribed in Income-tax Act, 1961. - At this stage, we also note that the section 80P is a beneficial provision and the purpose is to incentivize the warehousing activity of co-operative societies. Therefore, the interpretation of section 80P must be liberal so as to advance the avowed objective. Taking into account all these aspects, we are persuaded to conclude that the income from letting of CAP storage derived by the assessee is eligible for deduction u/s 80P and there is no justification in denying the same to the assessee. Therefore, we delete the disallowance made by lower authorities. - AT
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