https://www.taxtmi.com/caselaws?id=5266 Receipt from the State Government for stocking and distributing ammonium sulphate was treated as income from letting out godowns and therefore exempt under section 14(3)(iv) of the Indian Income-tax Act, 1922. The Court read the provision as intended to encourage co-operative societies to construct and let out warehouses for storage of fertilisers and similar commodities. On the facts, the agreement showed that the dominant element of the arrangement was the use of the assessee's godowns for storage, while delivery and transport services were merely incidental. The payment being described as commission did not change its true substance, which was remuneration for use of the godowns. en-us Wed, 25 Jan 1989 00:00:00 +0530 Tue, 28 Oct 2025 15:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5266 Receipt from the State Government for stocking and distributing ammonium sulphate was treated as income from letting out godowns and therefore exempt under section 14(3)(iv) of the Indian Income-tax Act, 1922. The Court read the provision as intended to encourage co-operative societies to construct and let out warehouses for storage of fertilisers and similar commodities. On the facts, the agreement showed that the dominant element of the arrangement was the use of the assessee's godowns for storage, while delivery and transport services were merely incidental. The payment being described as commission did not change its true substance, which was remuneration for use of the godowns. Case-Laws Income Tax Wed, 25 Jan 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5266