Cooperative investment income and qualifying dairy equipment support statutory deduction and additional depreciation claims for the relevant assessment year.

Section 80P(2)(d) deduction is described as available for interest and dividend income earned from investments with cooperative societies and cooperative banks, based on an earlier decision concerning the same assessee. The note states that the third proviso allowing unavailed additional depreciation in the immediately succeeding year applied from 1 April 2016 and therefore covered Assessment Year 2016-17. It further treats milk cans, artificial insemination equipment and laboratory-testing equipment as plant and machinery eligible for additional depreciation where the remaining conditions are met. The discussed deductions and additional-depreciation claims are stated to remain available for the relevant assessment years.

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Issues: (i) Whether deduction under Section 80P(2)(d) was allowable on interest and dividend income from investments with cooperative societies and cooperative banks; (ii) whether the balance additional depreciation relating to machinery installed in the preceding year was allowable for Assessment Year 2016-17; and (iii) whether milk cans and artificial insemination and laboratory-testing equipment qualified as plant and machinery for additional depreciation.

Issue (i): Whether deduction under Section 80P(2)(d) was allowable on interest and dividend income from investments with cooperative societies and cooperative banks.

Analysis: The issue stood covered by the earlier decision in the assessee's own case. Income received from investments in cooperative societies and cooperative banks satisfied the statutory requirement for deduction.

Conclusion: Deduction under Section 80P(2)(d) was allowable. The issue was decided in favour of the assessee and against the Revenue.

Issue (ii): Whether the balance additional depreciation relating to machinery installed in the preceding year was allowable for Assessment Year 2016-17.

Analysis: The third proviso permitting the unavailed balance of additional depreciation in the immediately succeeding previous year took effect from 1 April 2016. As the matter concerned Assessment Year 2016-17, the statutory entitlement applied.

Conclusion: The balance additional depreciation was allowable. The issue was decided in favour of the assessee and against the Revenue.

Issue (iii): Whether milk cans and artificial insemination and laboratory-testing equipment qualified as plant and machinery for additional depreciation.

Analysis: The issue was governed by an earlier decision in the assessee's own case. Milk cans had been treated as plant for normal depreciation and fell within the definition of plant; therefore, additional depreciation could not be denied where the remaining conditions were met.

Conclusion: The milk cans and relevant equipment qualified for additional depreciation. The issue was decided in favour of the assessee and against the Revenue.

Final Conclusion: The deductions and additional-depreciation claims sustained by the appellate authorities remained available to the assessee for the relevant assessment years.

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