The meaning of godowns or warehouses for storage under section 80P of the Income Tax Act is not defined in the act itself. But we can take guidance from decisions by various high courts. Here are excerpts of courts orders in which the Hon’ble High Court tried to explain the meaning of godowns or warehouses for storage.
Meaning of godowns or warehouses for storage
The phrase ‘godowns or warehouses for storage’ used in section 80P of the Income Tax Act came up before various high courts as detailed under :
1. Hon’ble Gujarat High Court explained the meaning of ‘godowns or warehouses for storage ‘ while delivering judgment in CIT Vs. Ahmedabad Maskati Cloth Dealers Co-Operative Warehouses Society Ltd.  162 ITR 142 (GUJ.) as under :
Meaning : It will appear from the dictionary meanings of ‘godowns’ and ‘warehouses’ that both these are synonymous and interchangeable. The common parlance meaning which can be attributed to godowns or warehouses is that it must be used for the purpose of storage of goods even for temporary period. Shops in which wholesale or retail business in cloth is carried on, cannot, therefore, come within the meaning of ‘godowns’ or ‘warehouses’.
2. Hon’ble Allahabad High Court explained the meaning of ‘godowns or warehouses for storage ‘ while delivering judgment in CIT Vs. District Co-Operative Federation  271 ITR 22 (ALL.) as under :
Meaning : It will appear from the dictionary meanings of “godowns” and “warehouses” that both these terms are synonymous and interchangeable. The common parlance meaning which can be attributed to godowns or warehouses is that they must be used for the purpose of storage of goods even for a temporary period.
3. Hon’ble ITAT-Bangalore explained the meaning of ‘godowns or warehouses for storage ‘ while delivering judgment in Belgaum Gardeners Co-Op. Production Supply & Sale Society Ltd. Vs. Fifth ITO  7 ITD 247 (BANG. – TRIB.) as under :
Meaning : The meaning of ‘warehouse’ is a building or room for storing goods or merchandise. In respect of certain commodities in order to preserving them for long period from decaying, they are kept in an artificially cooled place, i.E., Cold storage. Thus, the cold storage is used for storing the goods. Merely because it has a refrigerating chamber, it does not lose the character of storing place, i.E., Warehouse. It is nonetheless a warehouse.
All that is to be seen is whether it is a place of storage of commodities. It is immaterial whether the place of storage is ordinary place of storing or artificially cooled refrigerating chamber. In either case it is only a place for storage of commodities. Once it is a place of storing, it comes within the meaning of warehouse. Hence, the cold storage where the commodities are stored for longer period without decaying would come within the meaning of ‘warehouse’.
4. Hon’ble ITAT-Nagpur explained the meaning of ‘godowns or warehouses for storage ‘ while delivering judgment in First ITO Vs. Pusad Ginning & Pressing Sahakari Society Ltd.  9 ITD 724 (NAG.-TRIB.) as under :
Meaning : A close scrutiny of the definition of term ‘warehouse’ would show that emphasis had been laid thereon in the storing of goods. Whereas a shop would be a place where goods are kept in display primarily for sale, a warehouse would be a place where primarily the goods are stored. The idea of sale which is predominant in the expression ‘shop’ is absent in expression ‘warehouse’.
In fact, the statute itself makes it clear by the juxtaposition of the two expressions ‘godowns’ and ‘warehouses’. Even if one considers that the shops would be synonyms for warehouses, condition no. (Iii) remains unsatisfied. This condition is that the letting out should be only for storage of the commodities or for processing or facilitating the marketing of the commodity. The shops cannot be considered as a place for storage of commodities. The shops are primarily places where customers can buy commodities. They are not premises where commodities are stored per se.
Section 80P of Income Tax Act
Deduction in respect of income of co-operative societies.
80P. (1) Where, in the case of an assessee being a co-operative society, the gross total income includes any income referred to in sub-section (2), there shall be deducted, in accordance with and subject to the provisions of this section, the sums specified in sub-section (2), in computing the total income of the assessee.
(2) The sums referred to in sub-section (1) shall be the following, namely :—
(a) in the case of a co-operative society engaged in—
(i) carrying on the business of banking or providing credit facilities to its members, or
(ii) a cottage industry, or
(iii) the marketing of agricultural produce grown by its members, or
(iv) the purchase of agricultural implements, seeds, livestock or other articles intended for agriculture for the purpose of supplying them to its members, or
(v) the processing, without the aid of power, of the agricultural produce of its members, or
(vi) the collective disposal of the labour of its members, or
(vii) fishing or allied activities, that is to say, the catching, curing, processing, preserving, storing or marketing of fish or the purchase of materials and equipment in connection therewith for the purpose of supplying them to its members,
the whole of the amount of profits and gains of business attributable to any one or more of such activities :
Provided that in the case of a co-operative society falling under sub-clause (vi), or sub-clause (vii), the rules and bye-laws of the society restrict the voting rights to the following classes of its members, namely:—
(1) the individuals who contribute their labour or, as the case may be, carry on the fishing or allied activities;
(2) the co-operative credit societies which provide financial assistance to the society;
(3) the State Government;
(b) in the case of a co-operative society, being a primary society engaged in supplying milk, oilseeds, fruits or vegetables raised or grown by its members to—
(i) a federal co-operative society, being a society engaged in the business of supplying milk, oilseeds, fruits, or vegetables, as the case may be; or
(ii) the Government or a local authority; or
(iii) a Government company as defined in section 617 of the Companies Act, 1956 (1 of 1956), or a corporation established by or under a Central, State or Provincial Act (being a company or corporation engaged in supplying milk, oilseeds, fruits or vegetables, as the case may be, to the public),
the whole of the amount of profits and gains of such business;
(c) in the case of a co-operative society engaged in activities other than those specified in clause (a) or clause (b) (either independently of, or in addition to, all or any of the activities so specified), so much of its profits and gains attributable to such activities as does not exceed,—
(i) where such co-operative society is a consumers’ co-operative society, one hundred thousand rupees; and
(ii) in any other case, fifty thousand rupees.
Explanation.—In this clause, “consumers’ co-operative society” means a society for the benefit of the consumers;
(d) in respect of any income by way of interest or dividends derived by the co-operative society from its investments with any other co-operative society, the whole of such income;
(e) in respect of any income derived by the co-operative society from the letting of godowns or warehouses for storage, processing or facilitating the marketing of commodities, the whole of such income;
(f) in the case of a co-operative society, not being a housing society or an urban consumers’ society or a society carrying on transport business or a society engaged in the performance of any manufacturing operations with the aid of power, where the gross total income does not exceed twenty thousand rupees, the amount of any income by way of interest on securities or any income from house property chargeable under section 22.
Explanation.—For the purposes of this section, an “urban consumers’ co-operative society” means a society for the benefit of the consumers within the limits of a municipal corporation, municipality, municipal committee, notified area committee, town area or cantonment.
(3) In a case where the assessee is entitled also to the deduction under section 80HH or section 80HHA or section 80HHB or section 80HHC or section 80HHD or section 80-I or section 80-IA or section 80J, the deduction under sub-section (1) of this section, in relation to the sums specified in clause (a) or clause (b) or clause (c) of sub-section (2), shall be allowed with reference to the income, if any, as referred to in those clauses included in the gross total income as reduced by the deductions under section 80HH, section 80HHA, section 80HHB, section 80HHC, section 80HHD, section 80-I, section 80-IA, section 80J and section 80JJ.
(4) The provisions of this section shall not apply in relation to any co-operative bank other than a primary agricultural credit society or a primary co-operative agricultural and rural development bank.
Explanation.—For the purposes of this sub-section,—
(a) “co-operative bank” and “primary agricultural credit society” shall have the meanings respectively assigned to them in Part V of the Banking Regulation Act, 1949 (10 of 1949);
(b) “primary co-operative agricultural and rural development bank” means a society having its area of operation confined to a taluk and the principal object of which is to provide for long-term credit for agricultural and rural development activities.
In this article, you can get guidance from high courts on the meaning of godowns or warehouses for storage under Section 80P of the Income Tax Act.