Extra shift depreciation for hotel restaurant machinery allowed where plant was used in business across shifts.

Extra shift depreciation allowance was available for plant and machinery installed in the restaurant section of a hotel because the claim turned on whether the machinery was installed and used in the business, not on the character of the activity carried on in the premises. The court noted that a hotel operating throughout the day may still involve different sets of workers in different shifts, so the shift concept is not excluded merely because the establishment is a hotel. The building not being treated as plant did not defeat the claim, since the allowance related to the machinery. The issue was decided in favour of the assessee and against the Revenue.

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Issues: Whether the assessee was entitled to extra shift depreciation allowance on plant and machinery installed in the restaurant section of its hotel.

Analysis: The allowance depended on the machinery being installed and used in the business, and not on the character of the activity carried on in the premises. A hotel working throughout the day can involve different sets of workers in different shifts, so the concept of shift is not inapplicable merely because the establishment is a hotel. The fact that the building itself may not be treated as plant did not affect the claim, since the allowance was sought for machinery and plant installed in the restaurant section.

Conclusion: The assessee was entitled to the extra shift allowance, and the issue was decided against the Revenue.

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