Broad construction of plant allowed development rebate for electrical installations used in business operations.

Electrical installations introduced in the conversion from D.C. to A.C. were treated as plant because the statutory definition of plant was construed broadly to include apparatus used for business, and the same meaning applied across related depreciation and rebate provisions. Poles, cables, conductors and switch-boards used for electricity distribution were therefore plant, and prior allowance of depreciation on such items supported that view. As the equipment was brought into position for use in the business, the installation requirement was satisfied, and development rebate was admissible on the expenditure incurred.

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Issues: Whether the electrical installations put in as part of the change from D.C. to A.C. system constituted plant, and whether development rebate was admissible on the expenditure incurred for such installations.

Analysis: The expression of plant in the relevant taxing provision was construed broadly in the light of the statutory definition, which is inclusive and wide enough to cover apparatus used for the business. The same words used in connected depreciation and rebate provisions were taken to bear the same meaning. Poles, cables, conductors and switch-boards used for distribution of electricity were treated as plant, and the fact that depreciation had been allowed on those articles supported that view. The installation requirement was also satisfied because the new electrical equipment was introduced and put in position for use in the business.

Conclusion: The electrical installations constituted plant, and development rebate was admissible on the expenditure incurred in connection therewith, in favour of the assessee.

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