Assessee-company had acquired and installed new plant and machinery in the preceding year and put them to use for less than 180 days. It claimed only 50 per cent of additional depreciation in the year of acquisition and claimed the balance 50 per cent in assessment year 2007-08 under section 32. Assessing Officer disallowed the balance 50 per cent claimed in assessment year 2007-08, treating the same as excess additional depreciation relating to assets used for less than 180 days in the preceding year. Tribunal affirmed the order of the Assessing Officer. On appeal, the Tribunal held that since additional depreciation is given to encourage purchase of new plant and machinery, as found in the Memorandum, the advantage of granting additional depreciation should be extended to all assessees without any discrimination, whether they used machinery for less than 180 days or more than 180 days in a particular assessment year. If assessee has used machinery for less than 180 days in a particular year, statute provides for 50 per cent of additional depreciation in that year, and remaining 50 per cent shall be allowed in the subsequent assessment year.(AY. 2007-08)