Electrical machinery classification under income tax rules excludes a diesel generator, making extra-shift allowance allowable.

A diesel generator installed in a factory was not treated as "electrical machinery" for the purpose of extra-shift allowance under the Income-tax Rules, 1962. The controlling construction was that electrical machinery is confined to machinery in which an electric motor forms a vital and inseparable part; equipment that merely generates electricity, or is operated by a diesel engine, does not fall within that excluded class on that basis alone. Applying that classification, the generator was outside the exclusion and the assessee's claim for extra-shift allowance was allowable.

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Issues: Whether a diesel generator installed in the assessee's factory is "electrical machinery" for the purpose of extra-shift allowance under the Income-tax Rules, 1962.

Analysis: The controlling test is whether the machinery is itself an electrical unit in which an electric motor forms a vital and inseparable part. Machinery that merely produces electricity, or is driven by a diesel engine, does not for that reason become electrical machinery. Applying this settled construction, a generator used in the factory was not treated as falling within the excluded category of electrical machinery for denying extra-shift allowance.

Conclusion: The generator was not "electrical machinery" within the relevant classification and the assessee's claim for extra-shift allowance was allowable.

Ratio Decidendi: For the purpose of the relevant depreciation classification, "electrical machinery" is confined to machinery in which an electric motor forms a vital and inseparable part; a generator or similar machine powered otherwise does not fall within that category merely because it generates electricity.

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