Law: Income Tax Ordinance, 1979

Section: ThirdSched.

Income-tax--Exemption---Depreciation---Buildings---"Work" and "workshop"--­Meanings---" Work" means any physical activity that means to obtain some end, the goal or the purpose and does not necessarily mean only a place of manufacturing process---" Workshop" as such is a place where some work is being carried on, be that for the purpose of manufacturing or not--­Restrictive meanings are to be allowed to the definition of "Factory or shop" in relation to an exemption clause, in respect of a facility provided by the Legislature in term of depreciation---Definition of the words "work" and "workshop" from such an angle would include the buildings which are utilized for the purposes which are not strictly manufacturing but are ancillary to the manufacturing process. (b) Income Tax Ordinance (XXXI of 1979)-- ----Third Sched., R.2(1)---Depreciation allowance---Factory and workshop--­Cold storage---Cold storage was covered under the definition of word "workshop" and it was entitled to depreciation @ 10%---Cold storage was an industrial. undertaking and was fully covered under the definition of "workshop" as it operated through a huge plant that manufactures a type of gas which maintains the freshness of the items placed therein and its natural shape for a longer duration than it could normally retain---Manufacturing of compressed gas for cooling the atmosphere within the area of the cold storage, was a "manufacturing process" cold storage was covered under the definition of the word "workshop" and was entitled to depreciation @10% . (c) Words and phrases--- ----"Work" and "workshop" ---Meanings. Webster's Comprehensive Dictionary, International Edn., Vol. Two by J.C. Ferguson ref. ORDER In this appeal petitioner the department assails reduction in rate of storage charges and conversion of depreciation from 5 % to 10% . D.R. says, that the I.T.O. had adopted per bag rate at Rs.105 against declared at Rs.97.80 which was in keeping view the fact that in a parallel case bearing NTN 23-2-0455852 rate per bag was adopted at Rs.100 in assessment year 1997-98 as well as in 1998-99. The argument of learned A.R. before First Appellate Authority as well as before me is that if in…

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