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The assessee is entitled to claim additional depreciation u/s 32(1)(iia) on electrical items forming part of plant and machinery, even if not engaged in manufacture or production. The Tribunal, following the Gujarat High Court's decision in CIT vs. Starlight Silk Mills Pvt. Ltd., held that AC plants, electric installations, and transformers are integral to plant and machinery and eligible for depreciation. Similarly, in Raw Flints (P) Ltd case, the ITAT Ahmedabad ruled that electrical installations are integral to the manufacturing process and cannot be excluded from plant and machinery. Accordingly, the assessee can claim depreciation and additional depreciation on electrical fittings constituting plant and machinery, subject to conditions u/s 32(1)(iia).
The assessee is entitled to claim additional depreciation u/s 32(1)(iia) on electrical items forming part of plant and machinery, even if not engaged in manufacture or production. The Tribunal, following the Gujarat High Court's decision in CIT vs. Starlight Silk Mills Pvt. Ltd., held that AC plants, electric installations, and transformers are integral to plant and machinery and eligible for depreciation. Similarly, in Raw Flints (P) Ltd case, the ITAT Ahmedabad ruled that electrical installations are integral to the manufacturing process and cannot be excluded from plant and machinery. Accordingly, the assessee can claim depreciation and additional depreciation on electrical fittings constituting plant and machinery, subject to conditions u/s 32(1)(iia).
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