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PRADEEP PARIKH, RAJPAL YADAV
Ganesh Alu Bhandar – Appellant
Versus
Income-tax Officer – Respondent
Pradeep Parikh, A.M. - In all these are six appeals in case of two assessees. In the case of Ganesh Alu Bhandar, there are cross-appeals, two each by the assessee and the department against the combined order of the learned CIT(A) dated 27-5-2002 for assessment years 1998-99 and 1999-2000. In case of Ashokkumar Narandas & Co., only assessee is in appeal against the combined order of the learned CIT(A) dated 27-5-2002 for assessment years 1998-99 and 1999-2000. Since the issues involved in all these appeals are common and inter-connected, we find it convenient to dispose of all the six appeals together by this consolidated order. The appeals of the assessees are taken up first for consideration.
2. Both the assessees have raised common grounds in their appeals. The first common ground is against holding that payment for use of cold storage is covered under section 194-I of the Income-tax Act, 1961 (the Act) and, therefore, tax was deductible on such payment.
3. The Assessing Officer observed that the two assessees had used part of the property owned by M/s. Vinayak Cold Storage (VCS for short) by keeping their goods in the said cold storage. In consideration thereof, the assessee
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