Investment allowance on computer-support air-conditioning upheld where the unit served factory operations, not office use.

Investment allowance under section 32A was held admissible for an air-conditioner installed in a factory cabin housing a computer. The equipment was found to be located in the factory area, not in office premises or residential accommodation, so the exclusion in section 32A(1)(a) did not apply. It was also treated as necessary for maintaining the computer's operating temperature and efficiency, rather than as an office appliance within section 32A(1)(b). The claim was therefore not barred on either ground, and the Revenue's appeal failed.

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Issues: Whether investment allowance under section 32A was inadmissible on an air-conditioner installed in the cabin where a computer was housed, either because it was installed in office premises or because it constituted an office appliance.

Analysis: The air-conditioner was found to be installed in the assessee's factory cabin where the computer was located, and not in office premises or residential accommodation. The prohibition in section 32A(1)(a) therefore did not apply. The air-conditioner was shown to be necessary to maintain the computer at the required temperature and working efficiency, and was not meant for office use in the sense contemplated by section 32A(1)(b). On these facts, it could not be treated as an office appliance.

Conclusion: The claim for investment allowance was admissible and was not hit by section 32A(1)(a) or section 32A(1)(b); the Revenue's appeal failed.

Ratio Decidendi: An air-conditioner installed in the factory area to ensure proper functioning of a computer is not an office appliance, and investment allowance is not denied merely because the equipment maintains the operating conditions of the computer.

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