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Issues: Whether deduction under section 32AB of the Income-tax Act, 1961 was allowable in respect of safe deposit lockers installed in a segregated strong room of the bank.
Analysis: The assessee, a scheduled bank, installed the lockers in a strong room kept apart from the administrative office area and meant only for locker operations. The place was treated as a segregated area where no administrative work was carried on, and the arrangement accorded with banking guidelines requiring lockers to be located in a separate strong room. On these facts, the strong room could not be regarded as part of the office premises so as to deny the statutory benefit.
Conclusion: The deduction under section 32AB was allowable and the disallowance was reversed in favour of the assessee.