Allowing the appeal the Court held that ; the Tamil Nadu Electricity Board had nothing to do with the registration of land, much less with its development or processing. Neither did the record reveal nor did the Department assert that the assessee purchased the land from TNEB. In order to install the wind turbine generators, the assessee must have excavated some earth on the land it purchased. Such excavation, did not amount to improving the land ; rather, it amounted to a preparatory step for erecting the wind turbines. Therefore, the land evacuation, if any, must be taken as part of infrastructure development for establishing the windmills. The depreciation  is allowable.( AY.2006 -07)