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income-tax Officer Vs. Sundaram Spinning Mills - Court Judgment

LegalCrystal Citation
CourtIncome Tax Appellate Tribunal ITAT Madras
Decided On
Judge
Reported in(1985)11ITD596(Mad.)
Appellantincome-tax Officer
RespondentSundaram Spinning Mills
Excerpt:
1. these two appeals by the revenue relating to the same assessee are heard together and disposed of by this common order. the assessee-firm is engaged in the business of manufacture and sale of yarn. the accounting year is the financial year.2. assessment year 1975-76 - the assessment was originally completed on 20-9-1978. total income determined was rs. 36,36,650. there was an appeal from that assessment. as a result of the appellate order, total income was revised to rs. 25,61,430. subsequently, the ito came to the view that the assessee was entitled to development rebate only at 15 per cent on its plant and machinery, whereas in the original assessment development rebate had been allowed at 25 per cent. the ito also came to be of the opinion that in respect of the machinery installed.....
Judgment:
1. These two appeals by the revenue relating to the same assessee are heard together and disposed of by this common order. The assessee-firm is engaged in the business of manufacture and sale of yarn. The accounting year is the financial year.

2. Assessment year 1975-76 - The assessment was originally completed on 20-9-1978. Total income determined was Rs. 36,36,650. There was an appeal from that assessment. As a result of the appellate order, total income was revised to Rs. 25,61,430. Subsequently, the ITO came to the view that the assessee was entitled to development rebate only at 15 per cent on its plant and machinery, whereas in the original assessment development rebate had been allowed at 25 per cent. The ITO also came to be of the opinion that in respect of the machinery installed prior to 31-5-1974, the assessee was not entitled to any initial depreciation whereas, such depreciation had been allowed in the original assessment.

According to the ITO the assessee's machinery had not been used for the purpose of manufacturing 'Textiles' listed in item 32 of the Fifth Schedule (which reads as under) and, hence, the above allowances in the original assessment had to be withdrawn : Textiles (including those dyed, printed or otherwise processed) made wholly or mainly of cotton, including cotton yarn, hosiery and rope.

3. The ITO in his reassessment order under Section 147(6) of the Income-tax Act, 1961 ('the Act'), completed on 11-3-1981 in appeal has recorded the view that a mere spinning mill such as that run by the assessee could not be said to be manufacturing textiles. Only where fabric or woven material was produced, it could be said to be a manufacturer of textiles. As the assessee manufactured only yarn, the machinery in question could not come under item 32 supra ; development rebate had, therefore, to be restricted to 15 per cent. Hence, the ITO withdrew the excess that had been granted in the original assessment.

4. The ITO, then referred to item 21 of the Ninth Schedule which reads as under : Textiles (including those dyed, printed or otherwise processed) made wholly or mainly of cotton, including cotton yarn, hosiery and rope.

Here again for the same reasons noted by him in connection with the withdrawal of the 'excess' development rebate allowed in the original assessment, he concluded that the assessee was not entitled to initial depreciation in respect of machinery installed during the previous year, on which initial depreciation had been allowed in the original assessment. The development rebate so withdrawn was Rs. 4,881 and the initial depreciation withdrawn was Rs. 38,691. The assesses appealed.

5. The basic contention taken before the Commissioner (Appeals) was that the action taken by the ITO, under Section 147(6) was itself illegal being without jurisdiction. The Commissioner (Appeals) accepted this ground. On this ground alone, he annulled the reassessment. In doing so, he noted the following : (a) The reasons recorded by the ITO in the order sheet for reopening the assessment under Section 147(6) were as under : Development rebate allowed at 25 per cent in respect of machinery.

Since the assessee is running a spinning mill only without weaving the articles manufactured, i.e., yarn, it cannot be said to be 'textiles' mentioned in item 32 of the Fifth Schedule. Hence, development rebate at 15 per cent is only admissible. The Commissioner (Appeals)'s decision for 1973-74 in the case of Kandasamy Spinning Mills has not been accepted by the department.

Second appeal has been filed. Since there was excess allowance of development rebate, income has escaped assessment.

For the same reasons, the assessee is not entitled to initial depreciation claimed as Rs. 38,691, since 'Textiles' mentioned in the Ninth Schedule cannot include yarn.

(b) The above clearly shows that there was only a change of opinion on the part of the ITO, with regard to the allowance of development rebate as well as the initial depreciation in the original assessment. No fresh information reached him within the meaning of Section 147(6), subsequent to the completion of the original assessment. All material facts were already there before the ITO at the time of the original assessment. It was only due to a change of opinion that action under Section 147(6), came to be taken.

Initiation of action under Section 147(6), was, therefore, without jurisdiction.

6. The Commissioner (Appeals) also went into the merits of the withdrawal of the development rebate as well as the initial depreciation. He observed as under : The ground against the disallowance of initial depreciation and development rebate at higher rate on certain machineries on the ground that the appellant as a manufacturer of yarn, cannot be considered as a manufacturer of 'Textiles' and, consequently the product manufactured by the appellant would not come under item 32 of the Fifth Schedule to the Act or item 21 of the Ninth Schedule to the Act, has to be allowed in view of the decision of the Tribunal (Bench'A'), dated 28-11-1981, in IT Appeal No. 250 (Mad.) of 1981 in the appellant's case itself for the assessment year 1976-77.

7. We have heard the parties. We find that as regards action under section 147(6), the Commissioner (Appeals)'s order cannot be faulted.

He applied the settled law in this matter. The records do not show that any information within the meaning of Section 147 reached the ITO after the completion of the original assessment. It appears, he merely took a second look at the facts already on record and then initiated action under Section 147(6). The Commissioner (Appeals) was right in holding that he had no jurisdiction to do so. Secondly, even on merits, the Tribunal's order of 28-11-1981 supra for the assessment year 1976-77 operates in the assessee's favour. Hence, we do not find any merit in the appeal by the revenue.

8. Assessment year 1978-79 - The dispute in this appeal relating to the cancellation of the interest levied under section 139(8) of the Act, The assessment order itself does not give the particulars of this levy.

But on the assessee's appeal, the Commissioner (Appeals) has discussed this issue in paragraph 5 of his order. He held in favour of the assessee with the following observations : The fifth ground is against the levy of interest under Section 139(8) of the Act. Having regard to the decision of the Madras High Court in the case of Rajyam Pictures v. Addl. CIT [1978] 114 ITR 847 and also having regard to the decision in the case of CIT v. City Palayacot Co. [1980] 122 ITR 430, this ground is entertained. It was contended before me that having regard to the fact that excess advance tax had been paid and refund had been granted to the appellant assessed in the status of a registered firm, it was not correct to levy interest under Section 139(8) of the Act. Keeping in view the spirit of the decision of the Madras High Court in the cases of Addl. CIT v. Marugan Timber Depot [1978] 113 ITR 993 and CIT v. Fomra Bros. [1980] 122 ITR 312, I hold that there was absolutely no justification for levy of interest under Section 139(8), when no tax was found to be payable by the appellant in the status of registered firm on completion of the assessment.

Consequently, I cancel the interest and allow this ground.

9. Shri C.S. Padmanabhan, the departmental representative, referred to Explanation 2 to Section 139(8). This provides that for the purposes of Section 139(8), where the assessee is a registered firm or an unregistered firm which has been assessed under Section 183(6) of the Act, the tax payable on the total income shall be the amount of tax which would have been payable if the firm had been assessed as an unregistered firm. The submission is that the ITO calculated the interest leviable under Section 139(8), on the basis authorised by the said Explanation and, hence, the levy should be maintained. For the assessee, Shri K. Ramagopal, the learned counsel referred to Section 139(8) itself. He points out that under this provision, the assessee is liable to pay simple interest at the stipulated rate on the amount of tax payable on the total income as determined on regular assessment, as reduced by the advance tax, if any, paid, and any tax deducted at source. In the instant case, the tax raised on regular assessment under Section 143(3) of the Act amounted to Rs. 2,00,193. On the other hand, the assessee had already paid advance tax of Rs. 2,59,900. In fact, after adjusting all the taxes due from the assessee, a refund of Rs. 39,204 was granted to the assessee. Hence, Section 139(8) was not attracted in such a case.

10. We have heard the parties. We are of the view that Explanation 2 cannot be read in isolation. In Addl. CIT v. Murugan Timber Depot [1978] 113 ITR 99, the Madras High Court held while interpreting the provisions of Section 271(1) of the Act, that the three penalty clauses, viz., (i), (ii) and (iii) of Section 271(1), indicate that the penalty contemplated by them is a measure of the tax payable by the assessee so that if no tax was payable by the assessee, no penalty can be levied on the assessee ; that the Legislature intended penalty as a deterrent to prevent evasion of tax and when there was no tax payable, there cannot be any evasion of tax and, therefore, there was no question of levying any penalty as a deterrent to the evasion of tax.

Secondly, in CIT v. Fomra Bros. [1980] 122 ITR 312, the Madras High Court held, that where the assessee had paid advance tax in excess of the tax assessed, there is no amount on which two per cent of the tax can be calculated as penalty under Section 271(1) {a){i){b). The Commissioner (Appeals) was, in our view, right in referring to these decisions to highlight the analogous purpose of Section 139(8) and to show that in a case like the one before us, levy of interest was not contemplated. Levy of interest provided for under section 139(8), is in the nature of compensation for delay in the riling of return and in the consequent payment due to the Government under Section 140A of the Act.

Where there is delay, the Act provides for levy of interest on the amount that is so due to the Government, but is withheld by the assessee by delaying the return. But in a case like this, where the advance tax already paid is much in excess of the tax, that is really due to the Government, to authorise levy of interest by reading Explanation 2 in isolation, would not be justifiable. We would, therefore, maintain the order of the Commissioner (Appeals).

1. I have gone through the order of my learned brother, Dr. S.Narayanan, the Accountant Member. I am in agreement with him in deciding the issues involved in the assessment year 1978-79, but it is my misfortune that I fail to do so in the assessment year 1975-76.

Thus, I say my say for the same as under (sic).

2. The assessee is a registered firm. The previous year relevant for the assessment year 1975-76 ended on 31-3-1975. The assessee, is a spinning mill and merely spins cotton thread. The assessee filed the return of income for the assessment year under consideration and made claims, inter alia, for higher development rebate and initial depreciation on the ground that the assessee made textiles of cotton by spinning cotton in as it manufacture yarn, by spinning cotton and thereby it manufactured yarn (sic). The ITO allowed the claim of the assessee.

3. However, thereafter, he reopened the assessment under Section 147 on recording the reasons that he had information that the allowance claimed and allowed to the assessee by him, in respect of development rebate and initial depreciation at the rate of 25 per cent, has escaped assessment of income for the assessment year under consideration, as the development rebate and initial depreciation is allowable to the assessee, on the facts and in the circumstances of the case, at the rate of 15 per cent.

4. In consequence of it, he issued a notice on the assessee under Section 147(b)/148 of the Act. In response to it, the assessee filed the return of income and thereby claimed that the assessee's spinning mills are spinning cotton and, therefore, manufacturing 'yarn' ; hence, the yarn is there as textile. Therefore, it was contended that the development rebate and initial depreciation originally allowed was justified. Furthermore, the reopening was not based upon any information rather on change of opinion. The ITO did not accept it and withdrew the development rebate and initial depreciation allowed by him at 25 per cent and sustained it at 15 per cent, holding therein that spinning cotton nowhere manufactures yarn which is to be taken as textile listed in item 32 of the Fifth Schedule and in item 21 of the Ninth Schedule.

5. In appeal, the Commissioner (Appeals) held, that there is no information for reopening the original assessment and the reopening of the assessment is based upon change of opinion ; so much so that assessee manufactures yarn in spinning the cotton. The revenue being aggrieved preferred this appeal. Shri C.S. Padmanabhan, the learned departmental representative, contends, that spinning of cotton is not yarn and, therefore, there is no question of taking it as textile.

Hence, the order of the Commissioner (Appeals) is erroneous in law and fact. On the issue of reopening of the assessment, his contention is that in allowing the higher development rebate and depreciation, the ITO had failed to apply his mind and therefore, there is no application of his mind, in view of the fact, that he made no enquiries and automatically allowed the claim of the assessee.

6. On hearing the parties and going through the records, it is clear from the record and being an admitted position that the assessee is a spinning mill, which spins thread from cotton, on the application of the machinery and plant for this purpose. There is no weaving machinery or plant therein. Thus, the admitted position is that cotton is spinned and thread is manufactured by the assessee (spinning mill) in the previous year of the assessment year 1975-76. Therefore, the question for our determination is that, whether such thread so manufactured by the assessee, by spinning the cotton, can be called or held to be 'yarn' to be taken as 'textile' for the purpose of development rebate and initial depreciation so allowed by the ITO in the original assessment.

7. The yarn to be taken as textile for the purpose of said allowances at the higher rate ; it should be so, as is required by the Ninth Schedule, item 21, and the Fifth Schedule, item 32, as produced in the order of my learned brother.

8. The bare reading of these shows that textile is that, which is to be made of yarn or yarn is to be woven into textile cloth to be textile.

Such textile or cloth of yarn is textile for the purpose of higher development rebate and initial depreciation as per the aforesaid Schedules. In the case of the assessee, the cotton is spinned and as such spinning of cotton manufactures merely thread (thread of cotton).

For the purpose of making it yarn, such thread is to pass through further chemical process or processes. Because such thread is kachha thread and it will not make at all textile or it cannot be woven into textile cloth. It has no strength to bear the labours or the movement of the shuttle and loom, i.e., hammering of the instruments of weaving to make the threads into cloth (textile) by the weaver either through hand (loom) or machinery (textile mill). This is all the minimum needed for the spun thread to be the yarn to make it into cloth or textile.

Thus, the spinned cotton or cotton thread of the assessee has to go for further processes of starching and refining, for the purpose of weaving it into cloth or manufacture of textile or fit for or to become the yarn (sic).

9. I am supported in taking the yarn, accordingly, by its meaning in the Chamber's Twentieth Century Dictionary, revised edn., page 1292, where yarn is "spun thread : one of the threads of a rope, or these collectively". In the Concise Oxford Dictionary on page 1514, the meaning of yarn is "any spun thread esp. of kinds prepared for weaving, knitting or rope making".

10. In this view of the matter, there is no doubt in my mind that the word 'yarn' to be included in textile is to be pucca thread and not kachha thread, (spinning of cotton). The kachha and pucca thread is used in the common parlance of weavers and textile industry. The kachha thread is not at all yarn. It becomes so, when it is made pucca by the weavers or manufacturer, under processes or under the chemical process or processes by starching and refining it. For instance, the thread which is used by the tailor in sewing the cloth for making pants, shirts, etc., may be said to be a pucca thread or yarn if so made from cotton. The spinning of cotton no doubt manufactures thread, but it is of no use ; even clothes cannot be sewed by it on account of its being useless. When this is so, then such thread cannot be taken at all as yarn as mentioned in the items of Schedule referred to above. Thus, at the most, the thread used by the tailors, for stitching and sewing the cloth, as stated above, can be called as yarn for this purpose if so made of cotton. Therefore, on the admitted position and totality of facts of the case, I hold that the assessee manufactured no yarn in the previous year relevant for the assessment year under consideration. In accepting the thread spinned from cotton by the assessee as textile or yarn, the ITO has failed to apply his mind and thereby allowed development rebate and initial depreciation at higher rate without making enquiries or investigation or research into facts or law ; but was not in fact obtained, resulting in escapement of income in the assessment year under consideration. Therefore, his action is justified under Section 147. Reliance can be placed on the decision of the Supreme Court in the case of CIT v. A. Raman & Co. [1968] 67 ITR 11.

11. No doubt much water thereafter has flown on it, but still its ratio is there and is also applicable to the attending and specific facts of this case being an admitted position that the assessee is manufacturing kachha thread by spinning cotton, which is not yarn or textile and to take it so, facts are to be collected, investigation and research in facts and law to be made, which the ITO failed to do in the original assessment.. Therefore, following it with respect, I hold that his action for reopening the assessment cannot be held without jurisdiction on the ground that he did so on a change of opinion.

12. Accordingly, I had a discussion with my learned brother, who has already recorded the opinion that there is a decision of the Tribunal in the assessee's own case. I have seen it and it is of the Special Bench, consisting of three Members. Therefore, the question is that whatever to be, we have to follow it ; whatsoever may be the circumstances (sic). Regarding it, I state that the Special Bench for the assessment year 1976-77 decided two issues. One of these is the issue which is before us ; while the another is regarding extra shift allowance. The Hon'ble Madras High Court has taken a different view on the issue of extra shift allowance in another case of South India Viscose Ltd. v. CIT [1982] 135 ITR 206, though there is no decision so far on the issue involved over here as stated above. The Special Bench, in deciding the issue, has relied on the decision of the Calcutta High Court in the case of CIT v. Shalimar Rope Works (P.) Ltd. [1980] 125 ITR 331, where the issue was that whether rope manufactured by the assessee is textile, but in the case before us it is not an admitted position that it is yarn. The admitted position is that thread is manufactured by spinning the cotton. Therefore, whether such thread is yarn or not, is the issue of controversy or dispute among the parties.

From the position on facts and from the order of the ITO, no other conclusion can be taken except holding that he took it that it is not yarn. This was not looked into by the Special Bench at all, as they took it as yarn an application of the decision of the Hon'ble Calcutta High Court (supra), where their Lordships, in interpreting the aforesaid Schedule, took the jute twins as jute rope. The Tribunal, therefore, concluded, on following it, that spinning of cotton manufactures yarn. The yarn is a pucca thread as is jute twins ; while spinning of cotton is merely a kachha thread without any strength and life and is of no use for making textile or cloth or rope and as such, it cannot be equated to jute twins where spinning of jute has further gone into processes for making jute twins. The order of the Special Bench further shows that there the admitted position was not that in the case of the assessee the spinning of cotton merely manufactures kachha thread as has been admitted in this year. Accordingly, I hold that the admitted facts in this year are distinguishable and the learned departmental representative has made new argument for it and demanded reconsideration. Accordingly, I hold that no higher rebate or initial depreciation is allowable to the assessee on taking the spinning cotton as yarn, on admitted position in place of kachha thread. However, keeping in mind the discussion with the learned Accountant Member, I hold that the case of this year is distinguishable with the assessment year 1976-77 and to be reconsidered, in view of the fact that question of law is involved and there was also question of law on the first issue decided by the Special Bench of the Tribunal and the High Court held that it requires reconsideration which is the duty of the Bench to do, being distinguished by the departmental representative as stated above and I have reconsidered it and on doing so, I hold that the ITO is justified in reopening and withdrawing the development rebate and initial depreciation allowed in the original assessment. In view of my above discussion and reasons thereto, I hold that the ITO is justified in reopening the assessment and withdrawing the development rebate and depreciation. Hence, I restore his order and set aside that of the Commissioner (Appeals) for the assessment year under consideration.

ORDER UNDER SECTION 255(4) OF THE INCOME-TAX ACT, 1961 - As we have differed in reason and conclusion in deciding this issue, therefore, I frame the question as under for reference to the President for referring it to the Third Member under Section 255(4) of the Act : Whether, on the admitted facts of the case, the spinning of cotton is kachha thread and, therefore, no manufacture of yarn is involved for taking it as textile for the purpose of higher development rebate and initial depreciation in the assessment year 1975-76 1. There being difference of opinion between the learned Members of the Tribunal, the following point has been referred to me for decision : Whether, on the admitted facts of the case, the spinning of cotton is kachha thread and, therefore, no manufacture of yarn is involved for taking it as textile for the purpose of higher development rebate and initial depreciation in the assessment year 1975-76 2. The assessee-firm carries on the business of a spinning mill. For the assessment year 1975-76, it claimed initial depreciation at 25 per cent under section 32(1)(vi) read with entry 21 of the Ninth Schedule.

Similarly, the assessee claimed higher development rebate at 25 per cent under Section 33(l)(b)(B)(i)(b), read with entry 32 of the Fifth Schedule of the said Act. The ITO allowed the claim of the assessee.

3. In order to appreciate the facts of the case properly, the aforesaid entries are reproduced below : Textiles (including those dyed, printed or otherwise processed) made wholly or mainly of cotton, including cotton yarn, hosiery and rope.

Textiles (including those dyed, printed or otherwise processed) made wholly or mainly of cotton, including cotton yarn, hosiery and rope.

4. The ITO was of the view that the assessee carried on the business of spinning yarn, that 'yarn' was not included in the expression 'textiles' appearing in the aforesaid entries and as such, the assessee was not entitled to initial depreciation and higher rate of development rebate. He, therefore, reopened the assessment under section 147(6) and withdrew the initial depreciation of Rs. 38,691 and the excess development rebate of Rs. 4,881.

5. On appeal, the Commissioner (Appeals) did not agree with the ITO. He observed that this was a case of mere change of opinion and as such, the ITO was not legally competent to reopen the assessment under section 147(6). On merits, he observed that the Tribunal had already held in the case of assessee in IT Appeal No. 25X) (Mad.) of 1981 for the assessment year 1976-77, that the assessee was entitled to initial depreciation because the expression 'textiles' included 'yarn'.

According to him, therefore, the assessee was entitled to initial depreciation and higher rate of development rebate in the present case.

6. Aggrieved by the order of the Commissioner (Appeals), the department went in appeal before the Tribunal.

7. The learned Accountant Member held that the Commissioner (Appeals) was right in holding that the assessment could not be reopened under Section 147(6) and that the assessee-firm was entitled to succeed on merits on the basis of the decision of the Tribunal in its own case for the assessment year 1976-77.

8. However, the learned Judicial Member did not agree with the learned Accountant Member. He observed that the expression 'yarn' meant 'pucca thread' and not 'kachha thread'. According to him, 'kachha thread' could be converted into 'pucca thread' only after starching and chemically processing the same. He further held that, since the assessee-firm manufactured merely 'kachha thread', it did not carry on the business of manufacture of 'yarn' and, hence, 'textiles' within the meaning of entries 21 and 32 of the Ninth and Fifth Schedules, respectively. He was of the view that this aspect of the matter was not taken into consideration by the ITO at the time of the original assessment and, hence, he could resort to the provisions of Section 147(b). For these very reasons, he remarked that the decision of the Tribunal in the case of assessee for the assessment year 1976-77 was distinguishable.

9. It is in these circumstances that the afore said question has been referred to me for resolving the dispute.

10. I have gone through the record and heard the learned representatives of the parties. I am unable to agree with the view of the learned Judicial Member. My reasons are not far to seek.

11. It would appear from the facts stated above that the department proceeded on the assumption that the assessee manufactured 'yarn'.

Neither the ITO nor the Commissioner (Appeals) made any distinction between 'pucca thread' and 'kachha thread' for arriving at the definition of 'yarn'. Again, even the learned Accountant Member of the Tribunal did not refer to this particular aspect of the matter. That being so, strictly speaking, the proposed question of difference does not arise either out of the facts of case or out of the orders of the learned Members of the Tribunal.

12. In any case, since the question has been referred to me, I would proceed to discuss the same in order to put an end to the controversy.

The expression 'yarn' as appearing in entries 32 and 21 of the Fifth Schedule and the Ninth Schedule is not defined in the Act. According to the Chamber's Twentieth Century Dictionary, 'yarn' means "spun thread : one of the threads of a rope, or these collectively". Similarly, Webster's New World Dictionary gives the meaning of 'yarn' as "any fibre as wool, silk, cotton, nylon etc. spun into strands for weaving, knitting or making thread". Again, the Oxford Dictionary defines 'yarn' as "any spun thread, specially of the kind prepared for weaving, knitting or rope making". It is evident that these dictionaries do not speak of any distinction between 'kachha thread' or 'pucca thread' for being included in the expression 'yarn'. The learned representative of the department has not brought to my notice any material to support the view of the learned Judicial Member that, for being 'yarn', the 'kachha thread' spun out of cotton must be chemically processed and made into 'pucca thread'. Even entries 21 and 32 of the Ninth and Fifth Schedules, supra, do not so require. In my opinion, therefore, the distinction made by the learned Judicial Member is without any basis.

I, accordingly, conclude that the expression 'cotton yarn' as used in entries 21 and 32 of the Ninth and Fifth Schedules merely means thread spun out of cotton and not necessarily 'pucca thread' after chemically processing 'kachha thread'. In this view of the matter, I hold that the assessee-firm carries on the business of manufacture of 'yarn' and, hence, 'textiles' within the meaning of the aforesaid entries.

13. For removal of doubts, I may state that in view of the decision of the Madras High Court in the case of CIT v. North Arcot District Co.

operative Spg. Mills Ltd. [19841 148 ITR 406 and the decision of the Tribunal in the case of the assessee itself, in IT Appeal No. 250 (Mad.) of 1981 for the assessment year 1976-77, the expression 'textiles' appearing in entries 21 and 32 of the Ninth and Fifth Schedules includes 'cotton yarn'. Accordingly, the assessee is entitled to initial depreciation and higher development rebate under Section 32(l)(vi) and Section 33(1)(b)(B)(i)(b) of the Act.

14. The case will now go to the Bench concerned for disposal according to law.


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