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    <title>2003 (6) TMI 204 - ITAT RAJKOT</title>
    <link>https://www.taxtmi.com/caselaws?id=71231</link>
    <description>Payments for use of cold storage facilities were held not to constitute rent for tax deduction purposes because a cold storage was treated as plant, not a building, under the income-tax provision. The reasoning rejected importing a labour-law fiction from the Factories Act into the income-tax context and confined the definition of rent to payments for land or building use, not plant use. As no tax was deductible on the cold storage charges, the consequential interest for non-deduction also could not be levied. The assessees accordingly succeeded on both the deduction and interest issues.</description>
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    <pubDate>Thu, 19 Jun 2003 00:00:00 +0530</pubDate>
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      <title>2003 (6) TMI 204 - ITAT RAJKOT</title>
      <link>https://www.taxtmi.com/caselaws?id=71231</link>
      <description>Payments for use of cold storage facilities were held not to constitute rent for tax deduction purposes because a cold storage was treated as plant, not a building, under the income-tax provision. The reasoning rejected importing a labour-law fiction from the Factories Act into the income-tax context and confined the definition of rent to payments for land or building use, not plant use. As no tax was deductible on the cold storage charges, the consequential interest for non-deduction also could not be levied. The assessees accordingly succeeded on both the deduction and interest issues.</description>
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      <pubDate>Thu, 19 Jun 2003 00:00:00 +0530</pubDate>
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