Extra shift depreciation turns on actual machinery use, not whether the entire plant worked triple shift.

Extra shift depreciation allowance under section 32(1)(ii) read with rule 5 is to be assessed with reference to the machinery actually used for the extra shift. The claim was confined to equipment that had in fact worked on triple shift, and the argument that the allowance could be denied for the entire undertaking unless all machinery operated on triple shift was rejected as illogical. The operative principle was that the allowance depends on actual use for the additional shift, not an all-or-nothing approach to the plant as a whole. On that basis, the allowance was treated as available for the machinery actually worked on triple shift.

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Issues: Whether extra shift depreciation allowance under section 32(1)(ii) of the Income-tax Act, 1961 read with rule 5 of the Income-tax Rules, 1962 was allowable in respect of machinery actually worked on triple shift even though the remaining machinery or plant did not work on triple shift.

Analysis: The claim was confined to the machinery that had in fact been used for the third shift. The contention that extra shift allowance could be denied altogether unless all machinery in the undertaking worked on triple shift was rejected as illogical. The governing principle applied was that allowance must be assessed with reference to the machinery actually used for the extra shift, not by an all-or-nothing rule for the entire plant.

Conclusion: The extra shift depreciation allowance was allowable for the machinery actually worked on triple shift, even though the other machinery or plant did not work on triple shift, and the question was answered in the affirmative against the Revenue.

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