Higher-rate depreciation on dyes and moulds upheld where evidence showed use in manufacturing plastic components for assembly products.

Higher-rate depreciation was allowed on dyes and moulds used to manufacture plastic components for assembling air coolers, ventilators and fans. The Tribunal and the Commissioner (Appeals) had found, on the evidence and the list of parts produced, that the assets were used in the manufacturing process, and the HC found no error in those concurrent factual findings. As the entitlement followed from those facts, the assessee qualified for the higher depreciation rate and no substantial question of law arose.

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Issues: Whether the assessee was entitled to depreciation at the higher rate on dyes and moulds used in manufacturing plastic components for assembly of air coolers, ventilators and fans.

Analysis: The Tribunal's finding was that the dyes and moulds were used in manufacturing various plastic components for assembling the assessee's products. That finding was recorded on appreciation of the evidence and the material placed on record, including the list of parts manufactured by use of those dyes and moulds. The High Court found no error in the concurrent factual conclusions reached by the Tribunal and the Commissioner (Appeals).

Conclusion: The assessee was entitled to the higher rate of depreciation, and no substantial question of law arose.

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