Gas cylinder classification for depreciation allowed on a truck-mounted ammonia container, with valves and regulators included.

A container mounted on a truck and used to transport liquified ammonia was treated as a gas cylinder for depreciation purposes because it was circular in shape, specially licensed for compressed ammonia gas, and fitted with valves and regulators. The classification turned on the container's form and function rather than its size, and the fact that a tanker ordinarily carries liquid in bulk did not change its character. The item therefore fell within the relevant depreciation entry, and 100 per cent depreciation was allowed on the cylinder together with its valves and regulators.

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Issues: Whether the container mounted on the truck used for transporting liquified ammonia was a "gas cylinder" falling within Appendix I, Part I, Item III(ii) F(4), and therefore eligible for 100 per cent depreciation together with its valves and regulators.

Analysis: The container was circular in shape, had the attributes of a cylinder, and was specially licensed for transporting compressed ammonia gas. A tanker was understood as a vehicle designed to carry liquid in bulk, whereas the container here was meant for gaseous matter and fitted with special valves and regulators. The size of the container did not alter its character, since a cylinder is identified by its form and function rather than by any minimum size.

Conclusion: The container mounted on the vehicle was held to be a gas cylinder within the relevant depreciation entry, and 100 per cent depreciation on the cylinder, valves, and regulators was allowed in favour of the assessee.

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