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Issues involved: Determination of reliefs and rebates on gross dividend income without deducting management expenses, entitlement to relief on interest from tax-free securities without deducting management expenses, classification of safe deposit vaults as "plant" for development rebate.
For the first and second questions regarding reliefs and rebates on gross dividend income and interest from tax-free securities, the court referred to a previous decision and ruled in favor of the assessee based on the precedent set by Commissioner of Income-tax v. New Great Insurance Co. Ltd. The court acknowledged the concession made by Mr. Joshi and answered both questions affirmatively in favor of the assessee. Moving on to the third question concerning the classification of safe deposit vaults as "plant" for development rebate, the court delved into the definition of "plant" under section 33(1) of the Income-tax Act, 1961. The court noted that the definition of "plant" is inclusive and covers various items used for business purposes. The court analyzed the meaning of "plant" from a dictionary perspective, highlighting that a safe deposit vault can be considered a fixture within the definition of "plant." The court also examined a previous decision regarding a water storage tank to contrast with the current case. The court ultimately concluded that a safe deposit vault qualifies as "plant" based on its usage in carrying on business activities. Citing relevant legal precedents, including a decision by the House of Lords, the court affirmed that a safe deposit vault is an apparatus used in business operations and therefore qualifies as "plant" for the purpose of development rebate under section 33 of the Act. Consequently, the court answered question No. 3 in the affirmative, ruling in favor of the assessee and directing the revenue to bear the costs incurred by the assessee in the legal proceedings.
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