Temporary erections in leased premises qualified for full depreciation, not lower-rate furniture and fixtures, on the facts found.

Wooden partitions and work stations installed in leased premises were treated as purely temporary erections where the alterations were intended to improve office utilisation and no contrary material showed a permanent character. On those facts, the assets fell within the item for purely temporary erections under Appendix I and qualified for 100 per cent depreciation; they were not to be treated as furniture and fixtures attracting a lower rate. The depreciation allowed by the CIT(A) was therefore upheld.

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Issues: Whether wooden partitions and work stations installed in leased premises were to be treated as purely temporary erections eligible for 100 per cent depreciation or as furniture and fixtures eligible only for lower depreciation.

Analysis: The expenditure was incurred on wooden partitions and work stations in premises not owned by the assessee and was intended to improve office space utilisation and working efficiency. No material was brought on record to dislodge the assessee's version that the alterations were temporary in nature. On those facts, the asset fell within item 4 of Appendix I relating to purely temporary erections such as wooden structures and was therefore entitled to depreciation at 100 per cent.

Conclusion: The wooden partitions and work stations were correctly treated as temporary erections and not as furniture and fixtures; the depreciation allowed by the Commissioner of Income-tax (Appeals) was upheld.

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