Special depreciation for motor lorries does not extend to borewell rigs and compressors mounted only for transport convenience.

Rigs and compressors mounted on lorries for drilling borewells do not fall within the expression "motor lorries" in the depreciation entry under the Income-tax Rules. The special 50 per cent depreciation rate applies only to articles that answer that description in common parlance and form an integral part of the vehicle. Equipment mounted on a lorry merely for transport convenience does not become a motor lorry, and an earlier binding decision on identical facts reached the same result. Accordingly, the higher depreciation rate is unavailable for such rigs and compressors.

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Issues: Whether rigs and compressors mounted on lorries for drilling borewells fall within the expression "motor lorries" in Entry III(ii) D(9) of Part I of Appendix I to the Income-tax Rules, 1962, so as to qualify for depreciation at the special rate of 50 per cent.

Analysis: The special depreciation rate applies only to articles answering the description of motor lorries. Rigs and compressors mounted on lorries merely for ease of transport do not become integral parts of a lorry, nor can they be treated as a lorry in common parlance. The earlier binding decision on an identical factual setting held that such rigs and compressors do not fall within the entry for motor lorries.

Conclusion: The rigs and compressors used for drilling borewells are not covered by the expression "motor lorries" and do not qualify for the special rate of depreciation; the question is answered in the negative and in favour of the Revenue.

Final Conclusion: The assessee is not entitled to the higher depreciation rate under the relevant entry for motor lorries.

Ratio Decidendi: An article mounted on a lorry for transport convenience does not become a motor lorry for the purpose of a special depreciation entry unless it is understood as such in common parlance and forms an integral part of the vehicle.

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