1983 (9) TMI 40

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..... m carrying on business in the manufacture and sale of manure mixtures. It is assessed to income-tax at Poona. It constructed a godown outside the municipal limits of Poona for being used in its business. Before the construction was completed, a firm named M/s. Parekh Traders requested (the assessee) that the godown be given to it on rent. There was no machinery nor plant fixed in the godown. Inste .....

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..... the godown is income derived from property. The instant case is, if at all, stronger on facts than was the case of M/s. Parekh Traders because in the instant case the assessee never actually utilised the godown for its own business purposes. For the same reasons that have moved us in deciding the case of Parekh Traders, we answer the question that is framed for our consideration, viz., " Whether, .....

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