1977 (6) TMI 40

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..... nished later it is found that the cost of one boat would be Rs.69,342 and the two boats Rs.75,000 each. The assessee claimed before the ITO depreciation at the rate of 20 per cent. In the books of accounts they had created development rebate of Rs.22,000. They claimed development rebate in respect of these boats also. 2. The ITO was of opinion that the assessee would be entitled to only 10 per .....

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..... defined as a motor driven boat by a high speed internal combustion engine capable of propelling the boat at a speed exceeding 24 kilometres per hour in still water and so designed that when running at a speed it will plane i.e. its bow will rise from the water. There is no material before us to show that the three boats satisfied these conditions. The certificate relied on by the assessee merely .....

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..... elied on for the interpretation of the word 'ship' appearing in that section. s.32 deals with depreciation on ships, machinery, plants, furniture and buildings. s. 33 which deals with development rebate confines itself to ships and machinery and plant. It would be reasonable to assume that the word 'ship' in s. 33 has the same meaning as in s. 32. The meaning attributable to that word in s. 32 bei .....

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