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Issues: Whether a tube-well installed for business use constitutes "plant" and whether the assessee was entitled to investment allowance on its cost.
Analysis: A tube-well is an apparatus used for drawing water from subterranean sources, and the water drawn was necessary for production as well as industrial labour. In that context, it falls within the wide meaning of "plant" under section 43(3) of the Income-tax Act, 1961.
Conclusion: The assessee was entitled to investment allowance on the cost of the tube-well.
Ratio Decidendi: A tube-well used in the business and employed for production-related purposes is "plant" within the meaning of section 43(3) of the Income-tax Act, 1961.