- (1.) Having heard learned counsel for the parties in these appeals, which pertain to the assessment years 2007-08 and 2008-09, we frame the following substantial question of law:-- Whether the Income Tax Appellate Tribunal is right in holding that items mentioned under the heading 'electrical installations' are entitled to depreciation @ 10% under the heading 'electrical fittings' and not @ 15% under the heading 'plant and machinery'. As a short and limited issue arises for consideration, we dispense with the requirement to file paper books and documents and take up the appeals for final disposal with the consent of the parties at this stage itself.
(2.) The appellant-assessee is engaged in the business of manufacture of steel metal components, assemblies and sub-assemblies primarily for automobiles and white goods sector. Along with the return, the appellant had filed copy of the balance-sheet and had claimed depreciation under the heading 'electrical installations' @ 15%. The Assessing Officer, however, has held that depreciation @ 10% should be allowed on several items and he accordingly recomputed the depreciation.
(3.) The following chart for the assessment year 2007-08 gives details of items on which depreciation was claimed:--;