( 1 ) AT the instance of the Revenue, common questions couched almost in similar language have been referred by the Income-tax Appellate Tribunal for the opinion of this court for the assessment years 1978-79 and 1981-82. ( 2 ) FOR the sake of convenience, the question as referred in the reference relating to the assessment year 1978-79 is reproduced below : "whether, on the facts and in the circumstances of the case, the Appellate Tribunal was justified in law in holding that the assessee was entitled to triple-shift allowance in respect of the generator in terms of the Schedule of depreciation given under the Income-tax Rules, 1962 ?" ( 3 ) SECTION 32 (1) of the Income-tax Act, 1961 (briefly, "the Act"), states that in respect of depreciation of buildings, machinery, plant or furniture owned by the assessee and used for the purposes of the business or profession, the following deductions shall, subject to the provisions of Section 34, be allowed. ( 4 ) IT is, therefore, clear from Section 32 that depreciation is allowable on machinery, inter alia, which is owned by the assessee and used for the purposes of the business. ( 5 ) THE assessee in this case carried on the business of manufacture of Khandsari and, for that purpose, it owned machinery and a generator run by diesel. The Income-tax Officer himself allowed normal depreciation on the generator to the assessee, but denied extra shift allowance on that for the reason that the same constituted "electrical machinery". The question for consideration is whether the generator owned by the assessee constituted "electrical machinery", which is not entitled to extra shift allowance. The assessee then went up in appeal and the appellate authority affirmed the order of the assessing authority. However, on further appeal, the income-tax Appellate Tribunal accepted the contention of the assessee and held that the generator was not "electrical machinery", though it generated electricity. ( 6 ) SRI Rajesh Kumar Agarwal, learned counsel for the Revenue drew our attention to a decision of the Madras High Court : CIT v. M. S. Sahadevan [1980] 123 ITR 820, connected with other matters. In M. S. Sahadevan [1980] 123 ITR 820, the assessee carried on the business of running a calendar press, printing press, offset printing press, etc. In M. S. Sahadevan [1980] 123 ITR 820, the assessee carried on the business of running a calendar press, printing press, offset printing press, etc. , and, in that case, a question arose as to what is the correct meaning of the words "electrical machinery". The Madras High Court held that wherever the machinery is such that in-built into it is the electric motor, then it would be electrical machinery. The Madras High Court further observed that, for instance, a mono-bloc, which is worked electrically with the aid of the in-built motor, is electrical machinery. So it is laid down by the said court that, if the machinery has an in-built motor and operates electrically, then the same would be electrical machinery. We are in respectful agreement with such a view taken by the Madras High Court. Let us apply the said test to the generator owned by the instant assessee. The generator generates electricity, but no in-built motor is fitted into it and it is not operated by electricity and, therefore, the same cannot be said to be electrical machinery. The assessing authority was, therefore, not right in holding that the generator did not qualify for extra shift allowance. ( 7 ) FOR the above reasons, the aforesaid common question referred to us is answered in the affirmative, that is, in favour of the assessee and against the Revenue. No order as to costs. .