COMMISSIONER OF INCOME TAX Vs. JAGSON INTERNATIONAL LTD.

JUDGEMENT

(1.) DELHI Bench 'D' Delhi in ITA Nos. 1690 to 1693/Del/2004 relevant for the asst. yrs. 1996 -97 to 1999 -2000.

(2.) THE assessee had purchased a vessel called a 'Deep Sea Matdrill', which is a shipping vessel with a drilling rig

(3.) IN the asst. yr. 1994 -95, an issue came up for consideration whether the vessel was a ship or not. In the assessment order passed for that year, the AO took the view, after discussing the matter with a representative of the assessee, that the vessel in question was a ship and, therefore, he allowed 20 per cent depreciation claimed by the assessee. It was noted by the AO that the vessel was actually a barge with a drilling rig installed on it. It was mobile and could be used for offshore drilling. It was, therefore, held that the assessee was entitled to claim a deduction under s. 33AC of the IT Act, 1961 (for short 'the Act').