Investment allowance denied for cinema projector and air-conditioning plant, as neither asset was used in manufacture or production.

Investment allowance under section 32A was confined to plant or machinery installed and used for the manufacture or production of an article or thing. A cinema projector only projects films and does not produce any article or thing, and an air-conditioning plant used for spectator comfort is likewise outside the provision. The assessee was therefore not entitled to investment allowance on either asset.

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Issues: Whether a cinema theatre assessee was entitled to investment allowance on a cinema projector and an air-conditioning plant installed in the theatre.

Analysis: Investment allowance under section 32A is available only where the plant or machinery is installed and used for the manufacture or production of an article or thing. A cinema projector merely projects films and does not bring into existence any article or thing. The air-conditioning plant is installed only to provide comfort to spectators and is likewise not used in manufacture or production.

Conclusion: The assessee was not entitled to claim investment allowance on either the projector or the air-conditioning plant.

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