100% depreciation on fluidized bed energy-saving plant allowed despite boiler-dryer distinction

100% depreciation was treated as allowable on a fluidized bed type heat dryer because the depreciation table referred to a fluidized bed type heat boiler, but the plant operated on the same fluidized-bed principle and served the same energy-conservation function. The distinction between a boiler and a dryer was held immaterial for the depreciation benefit, and the issue was also covered by the Tribunal's earlier decision in the assessee's favour.

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Issues: Whether depreciation at 100% was allowable on a fluidized bed type heat dryer as an energy-saving plant.

Analysis: The depreciation table expressly referred to a fluidized bed type heat boiler, but the plant in question operated on the same fluidized-bed principle and served the same energy-conservation purpose. The distinction between a boiler and a dryer was held to be immaterial for the applicable depreciation benefit, and the issue was also covered by the Tribunal's earlier decision in the assessee's favour.

Conclusion: Depreciation at 100% was correctly allowed on the fluidized bed type heat dryer.

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