1980 (9) TMI 148

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..... preciation on diesel generator at the special rate of 15 per cent as applicable to general machinery employed in tea factories. The ITO allowed depreciation on generator at 10 per cent on the basis that it is not an item of machinery coming under the category of general machinery in Tea factories appearing in the depreciation schedule. The CIT (A) considered that the assessee is eligible for depre .....

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..... eral machinery and plant' occurring after the expression 'Tea factories' quite definitely means that all machinery and plant involved in the manufacturing process would be comprehended by the Entry. He has drawn support by examining certain other entries and has psychically referred to item (ii)(E)(2) which reads "Rubber and plastic goods factories-Moulds" and has observed that here in this partic .....

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..... ctory and, therefore, the generator and the electricity produced from the generator could not have in fact been used in the tea factory for the purpose of processing the tea. It is on the other hand pointed out by the ld. counsel for the assessee that the generator is only in the factory, that the firm wood is burnt to generate steam to dry the tea leaves and the generator is used to produce elect .....

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