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TMI Blog2015 (7) TMI 939X X X X Extracts X X X X X X X X Extracts X X X X ..... tems which form part of the plant and machinery. These items are not simple electrical fittings, for example industrial cables, power distribution board, control cabin, converter panel, etc. do not have standard alone function. They are part of the plant and machinery. The electrical fittings as mentioned by the Income Tax Rules on which depreciation is specified at 10% are such items which can function on a standard alone basis such as fan, light and the attachments thereto representing wires, switches, etc. The items which have been mentioned in page 2 of the assessment order clearly are not simple electrical fittings. These go to form part of the plant and machinery. Consequently the same would have to be held to be eligible for deprecia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion, the assessee has challenged the reopening of assessment. 4. At the time of hearing, it was submitted by the ld. CIT, D.R. that the issue in the Revenue s appeals was against the action of the ld. CIT(Appeals) in directing the Assessing Officer to allow depreciation on electrical installation by holding the same as plant and machinery. It was the submission that in the course of assessment, it was noticed that the assessee had started the business of manufacturing of MS Billet and TMT Bars and Coke. The assessee had claimed depreciation @ 15% on the electrical installations and further additional depreciation of 10%. It was the submission that the Assessing Officer had held that the electrical equipment was eligible for depreciation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wer distribution board, control cabin, converter panel, etc. do not have standard alone function. They are part of the plant and machinery. The electrical fittings as mentioned by the Income Tax Rules on which depreciation is specified at 10% are such items which can function on a standard alone basis such as fan, light and the attachments thereto representing wires, switches, etc. The items which have been mentioned in page 2 of the assessment order clearly are not simple electrical fittings. These go to form part of the plant and machinery. Consequently the same would have to be held to be eligible for depreciation at the rate provided for plant and machinery. A perusal of the order of the ld. CIT(Appeals) clearly shows that the ld. CIT(A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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