Depreciation entitlement: full allowance where assets are used for business purposes despite idle periods; apportionment by operation time not required.

Entitlement to full depreciation under Section 10(2)(vi) turns on whether the asset is "used for the purposes of the business"; the term "used" includes passive or idle availability in furtherance of business, so machinery kept ready or unused at times may still qualify. Section 10(3) limits allowance only where the asset is used for non business purposes, not merely because it was not operated throughout the year. Applying that construction, the assessee is entitled to full depreciation and the Tribunal's allowance is upheld.

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Issues: Whether, on the facts found, the assessee is entitled to the full depreciation allowance under Section 10(2)(vi) of the Income-tax Act.

Analysis: Section 10(2)(vi) allows depreciation in respect of buildings, machinery, plant or furniture "used for the purposes of the business, profession or vocation"; when read with sub-clause (iv) the term "used" encompasses use for the purposes of the business, which may include passive as well as active user. Viswanath Bhaskar Sathe v. Commissioner of Income-tax supports a construction where machinery kept ready or idle in furtherance of the business may still be "used" for business purposes. Section 10(3) restricts allowance where the asset is "not wholly used for the purposes of the business" in the sense of being used for other purposes, not merely because it was not operated throughout the year. The statutory language does not mandate apportionment of depreciation by the exact period of operation during the year.

Conclusion: The assessee is entitled to the full depreciation allowance under Section 10(2)(vi); the Tribunal's allowance is upheld.

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