TMI Blog1984 (7) TMI 171X X X X Extracts X X X X X X X X Extracts X X X X ..... nd machinery insofar as the printing work is concerned. The ITO under the direction of the IAC made the disallowance on account of investment allowance relatable to the Table Ghar account as according to him it was not part of the plant and machinery. 7. The CIT (A) after considering all these facts held that expenditure on Table Ghar account and table account is necessary for the printing work plant because through the Table Ghar account facts, are installed which are necessary over the printing tables and as such the whole unit form plant and machinery. Accordingly, he granted the investment allowance even on the Tables Ghar account. 8. Before us Shri Saxena, ld. Departmental Representative said that the CIT (A) though has observed in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hri Ranka. The cases which have been referred by him are of little help of him. In the first case decided by the Allahabad High Court it was a case of Cold Storage wherein the entire walls were made of special kind of insulation. It was in that context that their Loardships had held that the insulated walls are part of the plant and machinery. In the other case cited i.e., Taj Mahal Hotel decided by the Supreme Court, the case was in connection with various pipe lines fitted in the hotel premises whether that constitute plant or not. If we have to accept Mr. Ranka s argument we would be faced with the situation where all factory building would stand in the same footing as plant and machinery. Wherever plants are installed, it requires struc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or printing work because of constant usage the engravings wear out and there is a consequence of weight reduction in the copper rolls. The CIT (A) was of the view that copper roll was a consumable item and in view of the furtherance of trade done of the assessee he allowed this claim of Rs. 24,508 and deleted the addition of Rs. 74,438. 11. Before us Shri Saxena urged that in one of the cases which was similar in nature the Jaipur Bench of the Tribunal had held that copper rolls are capital in nature and are entitled only to depreciation. Shri Ranka on the other hand urged that any reliance placed by the Department in any case a copy of the same should be made available so that it was possible for him to pinpoint the difference if any bet ..... X X X X Extracts X X X X X X X X Extracts X X X X
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