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47. As regards the assessee's claim for allowing depreciation @ 60% on CTP, it is noticed that section 32(1)(iia) of the Act provides for allowing additional depreciation in the case of any new machinery or plant acquired and installed after 31.3.2005 by an assessee engaged in the business of manufacture or production of any article or thing, etc. The AO has recorded a categorical finding in not accepting the assessee's claim for additional depreciation to the effect that: 'computer and computer software is out of the ambit of plant and machinery.' When we look at Appendix to Income-tax Rules, it turns out that Item at Sr. No. III in new Appendix I is: 'Machinery and plant.' Item at Sl. no. (5) covered under Item III of the Appendix is: 'Computers including computer software.' Thus, it is ostensible that the viewpoint of the AO that the computers are not to be considered as part of the machinery for the purpose of additional depreciation, is not sustainable. The legislature has not specifically excluded computers used in factory from the ambit of 'new plant and machinery' eligible for additional ITA Nos.2508, 2203, 2202, 2507/Del/2012, ITA Nos.986 & 340/Del/2012.

depreciation @ 20%. We, therefore, approve the view taken by the ld. CIT(A) in directing to allow additional depreciation on CTP at 20%.

48. As regards the assessee's grievance about not allowing depreciation on CTP at 60%, we are unable to find out anything in the language of the section or the Rules by which an item of Plant and machinery which calls for depreciation at a higher rate becomes ineligible for additional depreciation. Here is a case in which the assessee used CTP processor and CTP software for converting the data of printing plates for use in printing press as master pages. In other words, CTP performs the functions of receiving and processing data ready for printing process. The CTP is nothing but part of machinery used by the assessee in its business of printing press in the factory itself. Since CTP is otherwise an item of plant and machinery, but, falls under the broader head of 'Computers including computer software,' which is subject matter of item (5) under the broader heading 'III of Appendix I,' we hold that the assessee is entitled to depreciation on CTP at higher ITA Nos.2508, 2203, 2202, 2507/Del/2012, ITA Nos.986 & 340/Del/2012.