The Gujarat High Court in  19 ITR-OL 438 (Guj) came to the rescue of the taxpayer when the revenue challenged their claim for deduction of additional discounts offered on godown rent to the customers on the following grounds
- that those parties were owning their own godown in Mumbai
- the assessee was paying the rent to those parties in the form of discounts extended to them and such discount is subject to the provisions of section 194-I paying the rent in the garb of discounts.
Brushing aside such contentions the Court refused to go into the rationale of the discount which is a deduction being different from rent which fact is requiring verification as per directions issued by Commissioner (A) in this case. Thus on the revenue ground that section 194-I do not provide protection to such like discounts which are in the character of rent the Court declined to interfere at all given the free will to the taxpayer to run its affairs.