Assessee-company, engaged in business of manufacturing and sale of soft drinks, had purchased bottles and crates from various suppliers. For purpose of distribution to customers, soft drinks manufactured were filled in bottles and stacked in crates by assessee. Assessee claimed 100 per cent depreciation on such bottles and crates. Assessing Officer denied the claim of depreciation on ground that table of Plant and machinery under Income-tax Rules, 1962 framed under rule 5 does not have any reference of bottles and crates in listed items, therefore, same could not be considered as plant and rather should be treated as stock-in-trade. Tribunal affirmed the order. On appeal the Court held that  since ‘bottles and crates’ were used by assessee for bottling soft drinks manufactured by it, same would be included in definition of ‘plant’ and, thus, would be eligible for 100 per cent depreciation under section 32(1)(i) of the Act. Court also held that depreciation could not be disallowed merely on argument of revenue that bottles and crates could not be included in definition of ‘plant’ as they do not fall under categories listed in Income-tax Rules, 1962. (AY. 1989-90)