Printing rolls are not patterns, dies or templates for higher depreciation; only the lower rate applies.

Printing rolls were held not to fall within the depreciation entry for "patterns", "dies" or "templates" in Appendix I, Part I(III) of the Income-tax Rules, 1962. Applying the ordinary meanings of those terms, the court noted that a printing roll is only the substrate on which engraving is later done and is neither the model, the embossing instrument, nor the guide from which a design is formed; separate allowance of engraving charges did not change that character. The higher depreciation rate of 30 per cent. was therefore unavailable, and the asset was confined to depreciation at 10 per cent.

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Issues: Whether printing rolls are covered by Entry D-10 of Appendix I, Part I(III) of the Income-tax Rules, 1962 as "patterns", "dies" or "templates" so as to qualify for depreciation at 30 per cent., or whether they are admissible only at 10 per cent.

Analysis: The expressions "patterns", "dies" and "templates" were not defined under the Income-tax Act, 1961 or the Rules. Their ordinary dictionary meanings showed that a pattern is a model or sample, a die is an engraved stamp used for impressing a design on softer material, and a template is a pattern or guide used in shaping or cutting. Printing rolls, as such, do not answer any of these descriptions. They are not themselves patterns, because they are merely rolls on which engraving is subsequently done. They are not dies, because the rolls are not the instrument used to emboss or engrave. They are also not templates, because the rolls are not a model from which the design is formed. The fact that engraving charges were separately claimed and allowed did not alter the character of the rolls for depreciation purposes.

Conclusion: Printing rolls do not fall within Entry D-10 of Appendix I, Part I(III) of the Income-tax Rules, 1962, and depreciation at 30 per cent. is not admissible; only depreciation at 10 per cent. is allowable. The issue is decided in favour of the Revenue and against the assessee.

Final Conclusion: The reference was answered by holding that printing rolls are not entitled to the higher depreciation rate claimed under the relevant entry and are assessable only at the lower rate.

Ratio Decidendi: A depreciation entry referring to patterns, dies and templates must be applied according to the ordinary meaning of those terms, and an article that is merely the substrate on which engraving is done does not become a pattern, die or template for the purpose of the higher rate.

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