1984 (2) TMI 122

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....er s. 80P(2)(e) of the IT Act, 1961 ('the Act') in respect of; its income of Rs. 1,20,206. This represents commission received from the Karnataka Food and Civil Supplies Corporation for procurement of paddy and rice and reimbursement of transport charges. The ITO held that no part of its; income represents earning from letting of godowns or warehouses for the purpose of storage, processing or faci....

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....wer authorities. 3. We have considered the rival submissions. Secs.80P(1) and 80P(2)(e) read as under: "80P. Deduction in respect of cooperative societies:(1) Where, in the case of an assessee being a Cooperative society, the gross total; income includes any income referred to in sub-section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the s....

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....e word 'for' applies for 'processing' as well as 'facilitating the marketing of commodities'. If the intention was otherwise, the legislature would have used the word 'from' before 'processing'. The very fact that the word, 'for' is listed would indicate the letting of godowns or warehouses should be for storage, processing or facilitating the marketing of commodities and the income derived from l....

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.... governed by the preposition 'for' signifying that the letting of godowns or warehouses contemplated by the section is letting for any of the three purposes, namely, storage, processing or facilitating the marketing of commodities'. 4. The ratio laid down in the above case squarely applies to the instant case. In the instant case the assessee does not derive any income from letting of ;godown o....