A. Raghuvir, C.J.- This Reference is made under the Income-Tax Act, 1961 at the instance of the assessee - a Limited Company. The two questions referred read as follows : "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in holding that depreciation on concrete poles is to be allowed @ 10% in the assessment years 1977-78 to-1982-83 in terms of Appendix I of Part I of Rule 5 ? (2) Whether, on the facts and in the circumstances of the case, the Tribunal was justified in holding that the ITO was correct in revising the assessment under section 154 for the assessment years 1977-78 to 1080-81 ?" The assessee is a manufacturer of poles which arc used by the Electricity Department. The subject matter in the reference relates to moulds used for the manufacture of poles. In the assessment orders 1977-78 to 1980-81 the ITO allowed depreciation at thirty per cent on moulds and later corrected and allowed depreciation of ten per cent. The TTO similarly in the orders for 1981-82 and 1982-83 ordered 10% depreciation. On appeal by the assessee the CIT (Appeals) allowed the appeals and held : "There is not much difference between the concrete pipes and concrete poles and the assessee was entitled for depreciation at the rate of 30%". On further appeal the order of the ITO was restored by the Tribunal. The reasoning of tie Tribunal was that in Appendix I there is no specific provision for depreciation on moulds of the instant case therefore under residuary provision ten per cent depreciation only can be accorded. Hence the reference. Learned counsel for the assessee referred to Appendix I, Part I table in particular clauses 2 and 10 contained under the heading of "Machinery and Plant" and argued that the moulds of the instant case are covered by either of the two clauses. Clauses 2 and 10 read as under : "(2) Concrete pipes manufacture-Moulds (N.E.S.A) (10) Patterns, dies and templates (N.E.S.A.)" The counsel stressed that under clause 10 moulds of the instant nature are covered by the word template and in support of the assertion referred to the Oxford Dictionary which defines templates as under: "pattern, gauge, usually thin board or metal plate, used as guide in cutting or drilling metal, stone, wood, etc. ; timber or plate used to distribute weight in wall or under beam etc. ; molecular pattern governing assembly of protein etc." In the numerous clauses of Appendix I unless a specific clause is attracted in other case depreciation of ten per cent is to be allowed is not disputed. In commercial parlance pipes are far different from poles, therefore, sub-clause (2) has no application as that clause deals with moulds which are used for pipes therefore that clause is not attracted for the poles. By the same parity cf reasoning "templates" also does not cover the moulds for poles. In the result none of the two clause 2 or 10 are attracted. The conclusion reached by the Tribunal therefore is correct and call for no interference. The first question for the aforesaid reasons is answered in the affirma­tive in favour of the Revenue and against the assessee. The second question is covered by the decision of this Court reported in (1988) 2 GLR 341 (M/s. India Carbon Ltd., Gauhati vs. CIT Assam etc. Shillong). Following that case the question is answered in affirmative against the assessee and in favour of the Revenue. No costs.