Cinema theatre fittings as plant: auditorium installations and functional fixtures qualify, while ordinary building parts do not.

Cinema theatre components were examined to determine whether they qualified as "plant" under the Income-tax Act, 1961. Items designed and installed to support efficient film exhibition, including the auditorium screening wall and ceiling with sound-control features, were treated as plant. Furniture, fittings and fixtures within the auditorium, such as wooden walls, false ceiling, wooden panelling and chairs, were also brought within the plant concept for the relevant allowance. By contrast, ordinary building portions lacking that functional character, and chairs outside the auditorium, were excluded from plant treatment.

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Issues: Whether the various components of a cinema theatre, including the auditorium fittings and certain structural and decorative installations, constituted "plant" for the purposes of the Income-tax Act, 1961.

Analysis: The question turned on whether the items claimed by the assessee were so designed and installed as to serve the business function of exhibiting films efficiently, thereby qualifying as plant, as distinct from the ordinary building structure. Applying the earlier decision on the same type of theatre assets, the screening wall and ceiling of the auditorium, constructed with requisite installations for sound control and efficient screening, were treated as plant. Likewise, furniture, fittings and fixtures such as wooden walls, false ceiling, wooden panelling and chairs within the auditorium fell within the concept of plant for the relevant allowance. By contrast, parts of the building not having that functional character, and chairs outside the auditorium, were not included.

Conclusion: The answer was given in favour of the assessee only to the extent that the specified auditorium installations, furniture, fittings and fixtures were treated as plant; the remaining building portions and chairs outside the auditorium were excluded.

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