S.P.GOYAL, J.

1. This judgment will dispose of seven Income-tax Reference Nos. 30 to 32 of 1975 and 46 to 49 of 1975 as they involve a common question. References Nos. 30 to 32 relate to the Punjab Warehousing Corporation and the remaining to the Haryana Warehousing Corporation. The assessment years in case of the Punjab Warehousing Corporation are 1969-70, 1970-71 and 1971-72 whereas in the case of the Haryana Warehousing Corporation are 1968-69 to 1971-72. These warehousing corporations were established under section 18(1) of the Warehousing Corporations Act, 1962 , by notifications of the respective Government of Punjab and Haryana. The assessee-corporations were assessed to income-tax on the income derived by them from the letting of their godowns during each year of account under consideration by the Income-tax Officer and the plea of exemption under section 10(29) of the Income-tax Act (hereinafter called "the Act") was rejected. The order of assessment was upheld on appeal by the Appellate Assistant Commissioner. However, the Appellate Tribunal, relying on U. P. State Warehousing Corporation V/s. Income-tax Officer [1974] 94 ITR 129 (All) allowed the appeals of the a