Readiness for use can satisfy the put-to-use requirement for development rebate on plant or machinery.

Development rebate was considered available for two condensers received before the relevant cut-off date, even though they were not actually used during the year, because plant or machinery may be treated as put into use once it is ready for use. The controlling point was that actual replacement or physical deployment was not necessary where the machinery had been received and was fit for use. On that basis, the assessee was entitled to the development rebate on the condensers.

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Issues: Whether the assessee was entitled to development rebate on two condensers which were received before the relevant cut-off date but were not actually used during the year, on the ground that plant or machinery is treated as put into use once it is ready for use.

Analysis: The machinery was accepted to be in the nature of spares and there was no dispute that it had been received before the relevant date. The controlling question was whether actual replacement or physical deployment was necessary for the machinery to be regarded as put into use, or whether readiness for use was sufficient. The view taken was that in such cases plant or machinery is treated as put into use when it is ready for use, and not only when it is actually employed in operation.

Conclusion: The assessee was held entitled to development rebate on the two condensers.

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