Plant treatment for tram-car bodies fitted on old chassis supports additional depreciation and development rebate eligibility.

New tram-car bodies fitted on old chassis were treated as plant or machinery in their own right for depreciation-related allowances, because the statutory definition of plant was broad enough to cover vehicles and similar equipment. The special depreciation schedule for electric tramways also recognised car bodies as separately depreciable items, supporting the same character for allied allowances. On that basis, the installed bodies were regarded as distinct components qualifying for additional depreciation and development rebate.

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Issues: Whether new tram-car bodies installed on old chassis were machinery or plant by themselves so as to qualify for additional depreciation and development rebate.

Analysis: The relevant provisions treated machinery and plant as eligible for depreciation-related allowances, and the statutory definition of plant was wide enough to include vehicles and similar equipment. The special depreciation schedule for electric tramways also recognised car bodies as items separately eligible for depreciation. Since the new bodies were installed as distinct components and were already treated as plant for normal depreciation purposes, the same character applied for the allied allowances claimed under the Act.

Conclusion: The new tram-car bodies were plant or machinery by themselves, and the assessee was entitled to additional depreciation and development rebate.

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