06 April 2018
Cold storage is preserving perishable goods by mechanical process, and storage of such goods is only incidental in nature. The customer has no right to use any demarcated space/place or the machinery of the cold store and thus does not become a tenant. Therefore, the provision of 194-I is not applicable to the charges paid by the customers of the cold storage. Since the arrangement between the customers and cold storage owners are basically contractual in nature, the provision of section 194-C will be applicable to the amounts paid by the customers to the cold storage.
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