100 per cent depreciation for earthen salt pans allowed, with prior depreciation to be deducted from the present claim.

Earthen salt pans, reservoirs, roads and related units made of earth and clay qualify for 100 per cent depreciation, and the allowance does not depend on whether the assets were newly constructed or already existed before the relevant accounting year. The fact that the assets were not brought into use during that year did not defeat the claim. However, any depreciation already allowed in earlier years must be reduced from the present allowance to that extent. The Revenue's objection was rejected and the depreciation claim was accepted subject to prior allowances.

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Issues: Whether the assessee was entitled to 100 per cent depreciation on earthen work of salt pans, reservoirs, roads and related units even though the assets were constructed before the relevant accounting year.

Analysis: The Court followed its earlier decision holding that salt pans made of earth and clay qualify for 100 per cent depreciation and that the allowance does not depend on whether the assets are new or old. The Revenue's objection that the assets were not brought into use during the year of account was therefore rejected. The Court also noted that any depreciation already allowed in earlier years must be deducted from the present allowance to that extent.

Conclusion: The assessee was entitled to 100 per cent depreciation, subject to reduction by any depreciation already allowed in the past, and the question was answered in the affirmative against the Revenue and in favour of the assessee.

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