Data processing machines were not office appliances and therefore qualified for development rebate under income-tax law.

Data processing machines were not "office appliances" for purposes of exclusion from development rebate under section 33(1) of the Income-tax Act, 1961. The expression was construed in its ordinary commercial sense as referring to simple aids or facilities normally used for office functioning. The machines were highly technical systems requiring special installation, training and operating conditions, and one machine by itself had no commercial utility. As they performed complex processing operations and replaced intellectual labour rather than serving as ordinary office equipment, they fell outside the exclusion and qualified for development rebate.

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Issues: Whether data processing machines were office appliances so as to be excluded from development rebate under section 33(1) of the Income-tax Act, 1961.

Analysis: The expression "office appliances" was construed in its ordinary commercial setting as referring to simple aids or facilities normally used in an office for its functioning. The machines in question were highly technical systems requiring special installation, training, and operating conditions, and one machine by itself had no commercial utility. Their function was to perform complex processing operations and to substitute for intellectual labour, not to serve as ordinary office equipment. On that basis, they could not be equated with office appliances, and the Tribunal's factual findings supported that view.

Conclusion: The data processing machines were not office appliances and were eligible for development rebate under section 33(1) of the Income-tax Act, 1961.

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