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TMI Blog1983 (8) TMI 84X X X X Extracts X X X X X X X X Extracts X X X X ..... tric furnaces by treating them as 'machine tools' instead of general machinery. We will deal with these points separately in succeeding paragraphs. 2. We will first take up first objection relating to the items of expenditure of Rs. 32,256 and Rs. 50,652. The first amount was incurred on crane gantry supports and stanchions and their foundations. It was explained by the assessee's authorised representative, Shri R. K. Bansal, chartered accountant, that stanchions meant pillars and the entire expenditure related to the structure erected as supports for a travelling crane. The proper word may be a mobile crane fixed in the shed. In brief, the submission of Shri R. K. Bansal was that the structure was built to instal the mobile crane, and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... palli Sugars Ltd. v. CIT/CIT v. Hindustan Petroleum Corpn. Ltd. [1975] 98 ITR 167 which deals with the scope of expression 'actual cost'. The Supreme Court after taking note of accepted accountancy rule for determining cost of fixed asset has laid down that actual cost will include all expenditure necessary to bring such fixed assets into existence and to put them in working condition. Applying this test in respect of the mobile crane and the electric switch room sub-station for embedding the transformer the expenditure under both the heads would form part of actual cost of machinery. This being so, investment allowance will clearly become admissible in both the cases. We may also mention that so far as the second item of electric switch ro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 'A' furnaces figured under heading No. 6. Second publication of the Government of India relied upon was Hand Book of Indigenous Manufacturers of Engineering Stores - 11th edition, January 1972. This publication at item 81 had a heading of machine tools and accessories. Under this head 37 items were listed and 'Furnaces' figure at item (vii). On another page of the same publication the name of an engineering manufacturer manufacturing furnaces was given and from that party the assessee had purchased a furnace. The third publication of the Government of India is named Build Machines---Build India. In this Chapter IX is devoted to machine tools and accessories and at pages 50-51 the range of machine tools items is described and this also incl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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