M.C. JAIN, J.—The Income tax Appellate Tribunal, Jaipur Bench, has made this reference on reference application No. 85 and 86/JP/1974-75, arising out of I.T.A. Nos, 719 and 720/JP/1972-73, in respect of the assessment years 1969-70 and 1970-71, on the following questions of law:— 1. "Whether on the facts and in the circumstances of the case, the Tribunal was justified in holding that the assessee corporation was an authority constituted under any law for the marketing of commodities; and 2. " whether on the facts and in the circumstances of the case, the Tribunal was justified in holding that the income of the corporation from letting of godowns and/or warehousing was exempt from tax under Section 10(29) of the Income tax Act, 1961." 2. The Income-tax Officer was of the view that the assessee is not entitled to exemption under Section 10 (29) of the Income-tax Act and therefore, he added the income from letting of godowns and/or warehousing, in respect of the assessment years 1969-70 and 1970-71. The assessee went in appeal before the Appellate Assistant Commissioner and the Appellate Assistant Commissioner allowed the appeals and held that the assessee was entitled to exemption under Sec. 10(29), in respect of the income arising from letting of godowns and/or warehouses. The matter was taken up before the Income-tax Appellate Tribunal by the department and the Tribunal upheld the view of the Appellate Assistant Commissioner, whereupon reference applications were made on behalf of the revenue before the Tribunal. 3. At the very out set, it may be stated that there have been decisions of various High Courts on the point which we have been called upon to answer. Five High Courts, namely, Allahabad, Punjab and Haryana, Gujarat, Karnataka and Delhi have taken the view that Warehousing Corporations constituted under the Warehousing Corporations Act whether Central or State, are authorities constituted under the Warehousing Corporation Act for marketing of commodities and their income from letting of godowns & Warehouses would be exempt u/s. 10 (29) of the Income-tax Act. These decisions are U.P. State Warehousing Corporation v. I.T.O. (1), CIT v. Haryana Warehousing Corporation (2), Addl. CIT Vs. Karnataka State Warehousing Corporation (3), CIT vs. Gujarat State Warehousing Corporation (4). and Commissioner of Income-tax Delhi-II vs. Central Warehousing Corporation (5). 4. These decisions are U.P. State Warehousing Corporation v. I.T.O. (1), CIT v. Haryana Warehousing Corporation (2), Addl. CIT Vs. Karnataka State Warehousing Corporation (3), CIT vs. Gujarat State Warehousing Corporation (4). and Commissioner of Income-tax Delhi-II vs. Central Warehousing Corporation (5). 4. On behalf of the revenue, reliance has been placed on two decisions of Calcutta High Court, which are reported in Calcutta State Transport Corporation v. Commissioner of Income-tax West Bengal-IV. (6) and Singha Brothers P. Ltd. V. Commissioner of Income-tax, West Bengal-1, (7). 5. The main controversy arising in these matters centres round the expression "authority" under Section 10(29). What is required for the applicability of provisions of sec. 10 (29) is that it should be a body constituted under some law and it should come into existence for the marketing of commodities. If the body is constituted under the law with such an object, then it would be an autho-rity constituted under the law to which Sec. 10(29) would apply. The expression "authority" constituted for the purpose of marketing of "commodities" has been considered by the High Courts referred to above, other than Calcutta and we need not make further probe into the matter and deal with the question ourselves, We are in respectful agreement with the view taken by the High Courts referred to above. 6. So far as the Calcutta decisions are concerned, both the decisions are clearly distinguishable. They have been considered in the latest decision of the Delhi High Court in Commissioner of Income-tax, Delhi II v. Central Warehouse ing Corporation (Supra). The Calcutta State Transport Corporations case was a case wherein the expression "legal authority" was taken into consideration and so far as the second decision of the Calcutta High Court is concerned, it may be stated that, that was a case of joint stock company incorporated under the Companies Act and its primary object was to carry on ordinary business of commercial activity. Where is the assessee corporation in the present case, namely, Rajasthan State Warehousing Corporation is constituted under the Warehousing Corporations Act, 1962, promulgated by the Parliament, so the assessee corporation being a body constituted under the Central Act and carrying on the functions and exercising the powers under the Act is a body which is purely distinguishable from a company incorporated under the Companies Act. Even otherwise from considerations which weighed with the Calcutta High Court in connection with the expression "authority" were different, ft may be stated that the other High Courts have taken into consideration the expression "Authority" in a general way. A particular expression may assume a different meaning in a particular context. To us, it appears that when any body is constituted under any law with the object of marketing of commodities, then that body would be an authority and such an authority will be covered under Section 10(29). That body being a statutory corporation exercising the statutory powers and functions would be an authority entitled to claim exemption on income from letting of godowns and/or Warehousing. 7. We accordingly answer the two questions in favour of the assessee and against the revenue and we hold that the Tribunal was justified in holding that the assessee corporation is an authority constituted under the Warehousing Corporation Act, for the marketing of commodities and its income from letting out godowns exempt from the tax under Section 10(29) of the Act. 8. Parties shall bear their own costs.