Tea factory machinery depreciation applies to a diesel generator used in tea processing and power supply.

A diesel generator installed in a tea factory qualifies for the special depreciation entry for general machinery and plant used in tea factories where it is employed in the tea manufacturing process, including by supplying electricity to run processing motors. The use of firewood to generate steam did not displace the generator's functional role in tea production. Because the generator formed part of the factory's general machinery and was not expressly excluded from the applicable depreciation entry, it was treated as eligible for the special rate of depreciation for tea factory machinery.

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Issues: Whether a diesel generator installed in a tea factory is entitled to depreciation at the special rate applicable to general machinery employed in tea factories.

Analysis: The applicable depreciation entry covered "Tea factories - General machinery and plant including rollers and drivers" in Part I of Appendix I to the Income-tax Rules, 1962. The generator was found to be used in the factory for processing tea by supplying electricity to run the motors. The fact that firewood was also used to generate steam did not negate the factual use of the generator in the tea manufacturing process. Since the generator formed part of the general machinery of the tea factory and was not specifically excluded from the entry, it qualified for the special rate of depreciation.

Conclusion: The diesel generator was entitled to depreciation at 15 per cent as general machinery employed in a tea factory.

Ratio Decidendi: Machinery used in the processing of tea in a tea factory falls within the special depreciation entry for general machinery and plant unless expressly excluded.

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