100% depreciation on wooden shuttering upheld where item-wise purchases met the prescribed value limit and no substantial question arose.

Depreciation at the special rate of 100% was allowed on wooden shuttering used in construction, because the items were purchased under individual bills and each fell below the prescribed value limit for the statutory depreciation treatment. The Tribunal's acceptance of the claim was treated as a factual finding based on the character and use of the items, and that finding did not give rise to any substantial question of law. The 100% allowance was therefore upheld.

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Issues: Whether depreciation at the special rate of 100% was allowable on wooden shuttering under section 32(1)(ii) of the Income-tax Act, 1961, and whether the Tribunal's finding in that regard gave rise to any substantial question of law.

Analysis: The assessee had purchased several items for use in construction work, each supported by individual bills and each valued below the prescribed limit. On these facts, the Tribunal accepted the claim for 100% allowance under the statutory provision. The finding turned on the factual character of the items and their treatment for depreciation purposes.

Conclusion: The allowance of depreciation at 100% on wooden shuttering was upheld, and no substantial question of law arose.

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