Assessee is a co-operative society engaged in processing of milk and manufacturing of dairy products such as butter, ghee, pedha, etc.-During year under consideration, assessee made addition to plant and machinery. Assessee claimed additional depreciation under section 32(1)(iia) of the Act. The Assessing Officer took view that processing of milk does not fall under definition of manufacture and hence machinery purchased for processing of milk is not entitled for additional depreciation. Accordingly, he allowed additional depreciation on other machineries and disallowed additional depreciation claimed on machineries purchased for processing of milk. On appeal the Tribunal held that  provision of section 32(1)(iia) only states that assessee claiming additional depreciation under section 32(1)(iia) should be engaged in business of manufacture or production of any article or thing etc., however, it does not state that new machinery or plant should itself be used in manufacture of any article or thing.   Therefore, even though processing of milk will not result in manufacture of article or thing, assessee would be eligible for additional depreciation on plant and machinery used for processing of milk as assessee was a manufacturer engaged in production of diary products and Assessing Officer had allowed additional depreciation on machineries used for manufacture of dairy products which clarified that assessee was engaged in business of manufacture or production of any article or thing. (AY. 2014-15)