1989 (1) TMI 75

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..... ribution boards, etc., and sanitary pipeline installations in respect of thirteen new rooms constructed in the existing building on the ground that such installations should be considered as an integrated unit and depreciation allowed at 10% and that it was not correct to work out separately the cost of individual items of materials used and then to ascertain whether the cost did not exceed Rs. 750. On appeal by the assessee before the Appellate Assistant Commissioner, it was held that though switch boards, distribution boards, verandah lights, etc., could be regarded as items of plant or machinery, yet the expenditure incurred on the electrical system has to be treated as related to one integrated unit and cannot be split up into thirteen .....

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..... ground that the aggregate value of the installation was to be taken ?" Learned counsel for the assessee submitted that the question of depreciation on the electrical installations as well as sanitary pipelines and fittings provided for the rooms, constituting plant or machinery, has to be viewed separately with reference to each of the rooms put up and there was no justification for considering the switch boards, distribution boards, etc., making up the electrical system and the sanitary pipelines and fittings, etc., as an integral whole, to deny the assessee the benefit of the proviso to section 32(1)(ii) of the Act. On the other hand, learned counsel for the Revenue drew our attention to the method worked out by the assessee in claimin .....

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..... in our view, be too unreal and a wholly artificial approach as well. Thus, considering the electrical system as an integrated whole, the expenditure incurred on that has also to be treated as such and there is no scope for dissecting the electrical system into different component parts with reference to each one of the rooms and working out the depreciation in accordance with the proviso to section 32(1)(ii) of the Act. Similarly, the sanitary pipelines and fittings (with the exception of commodes, seat covers, flush tanks, etc., in each individual room, for which depreciation at 100% has been allowed) are intended to serve all the rooms as a whole and not only a particular room and have also to be regarded as one integrated unit and there .....

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