- (1.) This is an appeal filed by the Department.
(2.) The main dispute in this appeal relates to the question whether extra-shift allowance (ESA) is allowable in respect of the concern as a whole or in respect of each plant and machinery :
(3.) The AO calculated ESA in respect of each machinery depending on the number of shifts worked by such machinery, relying on the decision of the Madras High Court in South India Viscose Ltd. vs. CIT, 1982 135 ITR 206.;