https://www.taxtmi.com/caselaws?id=5326 Development rebate under section 33(1) is available only where the assessee both owns the plant or machinery and uses it wholly for its business during the relevant previous year. A reconstituted or successor firm is not automatically treated as the same assessable entity as the earlier partnership, and the benefit cannot be claimed unless legal ownership of the asset has passed to the claimant in a recognised form. On the stated facts, the assessee failed to prove ownership of machinery installed by the earlier firm, so the rebate was not allowable. en-us Fri, 07 Dec 1990 00:00:00 +0530 Fri, 05 Dec 2025 18:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5326 Development rebate under section 33(1) is available only where the assessee both owns the plant or machinery and uses it wholly for its business during the relevant previous year. A reconstituted or successor firm is not automatically treated as the same assessable entity as the earlier partnership, and the benefit cannot be claimed unless legal ownership of the asset has passed to the claimant in a recognised form. On the stated facts, the assessee failed to prove ownership of machinery installed by the earlier firm, so the rebate was not allowable. Case-Laws Income Tax Fri, 07 Dec 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5326