Ram Bahadur, J.M. - (1.) BOTH the appeals are directed against the order dt. 21st May, 1992 of CIT(A)-XVI, New Delhi, for asst. yrs. 1989-90 and 1990-91.
(2.) As both the appeals are by Revenue and have common Grounds and points of law, hence are taken together, heard and disposed of by a consolidated common order. Ground of appeal by Revenue are reproduced below : "1. On the facts and in the circumstances of the case, the learned CIT(A) has erred in : (i) directing the AO to allow investment allowance under s. 32A holding that the assessee is an industrial company. (ii) deleting the addition of Rs. 3,06,559 representing customs duty for the computers taken on hire despite the fact that the assessee was not owner and the hire charges were also high. (iii) directing the AO to allow the depreciation @ 100 per cent on down hole equipments despite the fact that the assessee-company is not a mineral oil concern."
(3.) THE brief facts of the case are that the respondent/assessee-company is engaged in carrying out full range of open hole and cased hole logging, perforation and other well-completion activities as well as formation evaluation and data processing services, etc. Wire logging operations are a high technology area in the mineral oil industry and form an essential tool of the work relating to oil exploration as by the wire-line logging operations, chemical parameters of the rocks concerning a well, that has been drilled are measured to assess the extent of oil reserves. Its depth is pinpointed and relevant information related lithology of the rocks is collected to formulate a plan for the development of oil reserves.;