This is departmental appeal. only issue is whether income derived from letting out certain premises would be exempt under section 80P(2)(e) of Income-tax Act, 1961 ('the Act'). 2. facts are as follows: assessee is co-operative society carrying on business of ginning and pressing of cotton for Maharashtra State Co-operative Marketing Federation. It appears that assessee had constructed few tenements which had been let out for different persons. One of these is let out to post office, another to Government office, third to doctor for running dispensary and rest to different shopkeepers. It is admitted position that in premises given to shopkeepers tenants are running regular business of buying and selling goods. total rent received from all premises was Rs. 58,344. out of this amount Rs. 12,686 represented rent from post office, dispensary, etc. In respect of balance, i.e., from shopkeepers, rent received was Rs. 45,658. 3. Before ITO, assessee claimed that Rs. 45,658 will be exempt under section 80P(2)(e). ITO found that these shopkeepers were small merchants dealing in cloth, stationery, kirana, etc. These premises are merely shops where day-to-day purchases and sales are carried out. According to him, these premises could not be considered as warehouse. He pointed out that in order to be eligible for exemption, there should be warehouse and warehouses should be used for marketing of commodities. commodities should be one manufactured or dealt with by concerned co-operative society. He, therefore, rejected assessee's claim and brought income to tax. 4. assessee appealed. Commissioner (Appeals) found that similar matter had come before Tribunal for assessment year 1976-77. T h e Tribunal was considering rent received from Apex Body, i.e., Maharashtra State Co-operative Marketing Federation. Tribunal had held that rent received will be exempt. Commissioner (Appeals) felt that same principle will apply in respect of rent received from tenants. 5. department is on appeal before us. Shri Verma for department submitted that Commissioner (Appeals) has not understood ratio laid down by Tribunal's decision. He submitted that tenants are ordinary shopkeepers purchasing and selling goods which had no connection at all with activities of co-operative society. He submitted that in order to be eligible for exemption tenants should deal with commodity which is connected with society. He then relied on decision of Gujarat High Court in case of Surat Vankar Sahakari Sangh Ltd. v. CIT [1971] 79 ITR 722 wherein Gujarat High Court has laid down that exemption is available only in respect of income derived from letting of godowns or warehouses where purpose of letting is storage processing or facilitating marketing of commodities. For assessee, Shri Atal, learned counsel submitted that expression 'warehouse' would cover shops which are subject-matter of dispute. He submitted that dictionaries had treated warehouse and shop as synonyms. He then pointed out that there are no case laws which referred to meaning of expression 'warehouse' in section 80P and, therefore, it would be correct to go by dictionary meanings. He then submitted that it is not necessary that commodity dealt in warehouse should be commodity in which assessee-co-operative society was connected. He then pointed out that in principle there is no difference between rent received from Apex Body which was dealt with by Tribunal for assessment year 1976-77 and t h e rent received from other tenants during accounting year. same principle would be applicable to both types of rent. 6. We have considered facts of case. Section 80P(2)(e) reads as follows: "in respect of any income derived by co-operative society from letting of godowns for warehouses for storage, processing or facilitating marketing of commodities, whole of such income;" conditions which must be satisfied before income could be exempt under this section are (i) income must be derived from letting, (ii) letting must be of godowns or warehouses, (iii) letting should be for storage, processing or facilitating marketing of commodities. It will be seen from section that three conditions have to be considered cumulatively. In order to be eligible for exemption, assessee should satisfy all three conditions. Now with this idea in mind, we can turn to facts of case. There is no difficulty in stating that first condition, i.e., premises being let out and income is derived from letting out, is satisfied. With regard to second condition, premises let out must be godown or warehouse. assessee's counsel had argued that shop is also warehouse. For this purpose he had relied on dictionary meanings. dictionary meanings laid down by him are given below: " Warehouse: Chambers Twentieth Century building or room for storing goods: Dictionary shop: As per Oxford building or part of building used for storage or merchandise. building in which wholesale dealer keeps his stock of goods for sale. Used as more dignified synonym for 'shop'. As per Websters Third Dictionary structure or room for storage of merchandise or commodities. wholesale establishment of service type in which large inventories are carried. " close scrutiny of above would show that emphasis had been laid thereon in storing of goods. Whereas shop would be place where goods are kept in display primarily for sale, warehouse would be place where primarily goods are stored. idea of sale which is predominant in expression 'shop' is absent in expression 'warehouse'. In fact, statute itself makes it clear by juxtaposition of two expressions 'godowns' and 'warehouses'. From this angle, it would be difficult for us to hold that shops in question would satisfy condition No. (ii). 7. Even if we consider that shops would be synonyms for warehouses, condition No. (iii) remains unsatisfied. This condition is that letting out should be only for storage of commodities or for processing or facilitating marketing of commodity. On facts of case, we need consider only whether premises are used for storage of commodities. Bombay High Court had occasion to consider meaning of expression 'storage' in case of Central Hindustan Orange & Cold Storage Co. Ltd. v. Prafullachandra Ramachandra Oza AIR 1967 Bom. 126. They had observed: " ...The ordinary meaning that would be given to word 'storage' is place for storing. That means any place where goods can be stored. It may b e that for different commodities different conditions of storage may be necessary.... but still all these places are places for storing various commodities and irrespective of conditions which may be obtaining in each of these places, they would all be called storages because what is done there is that actually goods or commodities are stored or kept for length of time.... " If we apply this test regarding storage, we find that shops cannot be considered as place for storage of commodities. shops are primarily places where customers can buy commodities. They are not premises where commodities are stored per se. 8. decision relied on by Shri Verma, departmental representative, clearly shows that extension of exemption provisions of section 80P is not called for. Gujarat High Court in case of Surat Vankar Sahakari Sangh Ltd. had made it clear that exemption is available only in respect of income derived from letting of godowns or warehouses where purpose of letting is only storage, processing or facilitating marketing of commodities. It, therefore, cannot be extended to any other purpose. 9. As departmental representative correctly pointed out, ratio of Tribunal's decision given for year 1976-77 cannot be applied to facts of case. Therein certain premises were let out to Apex Body of assessee-co-operative society for marketing. activities of assessee has some connection with activities of marketing federation. In other words, letting out is clearly for facilitating marketing of commodities to use expression given in section 80P(2)(e). Therefore, that case can be easily distinguished. 10. Under these circumstances, we allow departmental appeal. ITO's order will be restored. *** FIRST INCOME TAX OFFICER v. PUSAD GINNING & PRESSING SAHAKARI SOCIETY LTD.