Windmill depreciation principle: integral components of a turbine qualify for the higher depreciation rate, and the revenue's challenge failed.

Depreciation at the higher rate for windmill installations was held allowable on evacuation equipment, civil foundation work, electrical supply line and related items, because they were treated as integral and inseparable parts of the wind turbine generator. No contrary material was produced to displace the finding that these assets formed part of the windmill system eligible for the applicable 80% depreciation rate. The Assessing Officer's addition was deleted and the revenue's appeal failed.

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Issues: Whether depreciation at 80% was allowable on evacuation equipments, civil work of foundation, and electrical supply line and other items forming part of the wind turbine generator.

Analysis: The items in dispute were treated as components intrinsically connected with and forming part of the windmill installation. No contrary material or decision was shown to dislodge the finding that the assets were part of the wind turbine generator eligible for the higher rate of depreciation.

Conclusion: Depreciation at the higher rate was allowable on the disputed windmill-related items, and the revenue's grounds were rejected.

Final Conclusion: The addition made by the Assessing Officer was deleted and the revenue's appeal failed.

Ratio Decidendi: Assets that form an integral and inseparable part of a wind turbine generator are eligible for depreciation at the rate applicable to the windmill installation.

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