https://www.taxtmi.com/caselaws?id=26372 Gujarat HC held that rental income from letting shops to co-operative society members cannot be exempted under section 80P(2)(e) of the Income Tax Act. The court applied literal interpretation to "godowns or warehouses," ruling that shops used for textile business do not qualify as godowns or warehouses. The legislative intent was to encourage storage facilities, not commercial shops. The court rejected the argument that "facilitating marketing of commodities" could expand the meaning of godowns or warehouses beyond their literal interpretation. The Tribunal's decision granting full exemption was overturned, with matters remanded for consideration of alternative contentions. en-us Tue, 08 Oct 1985 00:00:00 +0530 Tue, 01 Jul 2025 17:47:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26372 Gujarat HC held that rental income from letting shops to co-operative society members cannot be exempted under section 80P(2)(e) of the Income Tax Act. The court applied literal interpretation to "godowns or warehouses," ruling that shops used for textile business do not qualify as godowns or warehouses. The legislative intent was to encourage storage facilities, not commercial shops. The court rejected the argument that "facilitating marketing of commodities" could expand the meaning of godowns or warehouses beyond their literal interpretation. The Tribunal's decision granting full exemption was overturned, with matters remanded for consideration of alternative contentions. Case-Laws Income Tax Tue, 08 Oct 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26372