Ordinary meaning of mineral oil governs depreciation claim; vegetable oil storage business could not access the higher allowance.

A storage and dealing concern in vegetable oil was held not to qualify as a mineral oil concern for 30% depreciation on well-head tanks. In the absence of a statutory definition, "mineral oil" was given its ordinary meaning as oil of inorganic origin, so plant-derived vegetable oil fell outside the expression. The alternative claim for a higher allowance also failed because the tanks were used only for storage, not processing, and mere contact with fatty acids in vegetable oil did not amount to contact with corrosive chemicals in the relevant sense. The special depreciation claim was therefore rejected.

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Issues: Whether a concern engaged in storage and dealing in vegetable oil can be treated as a mineral oil concern entitled to depreciation at 30% on well-head tanks under Item III-D(7), and alternatively whether the tanks qualified for the higher allowance on the footing that they came into contact with corrosive chemicals.

Analysis: The provision granting 30% depreciation applied to mineral oil concerns using well-head tanks. As the Income-tax Act did not define mineral oil, the term was construed in its ordinary and commonly understood sense. On that footing, mineral oil denoted oils of inorganic origin, whereas vegetable oil was a plant-derived organic product. The nature and use of the tanks, being for storage of vegetable oil only, did not bring the assessee within the class of mineral oil concerns. The alternative plea also failed because the tanks were not used in any processing activity and mere storage of vegetable oil containing fatty acids did not amount to contact with corrosive chemicals in the relevant sense.

Conclusion: The assessee was not entitled to depreciation at 30% under Item III-D(7), and the alternative claim for higher allowance also failed.

Final Conclusion: The assessee's claim to special depreciation was rejected and the Revenue's view was upheld.

Ratio Decidendi: In the absence of a statutory definition, a depreciation entry for mineral oil concerns must be applied according to the ordinary meaning of mineral oil, and a plant-derived vegetable oil storage business does not fall within that expression or within the related allowance for contact with corrosive chemicals.

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