V. K. GUPTA, J. ( 1 ) BY this common judgment we propose to dispose of the two Income tax references. being I. T. R No. 60 of 1992 and I. T. R. No. 128 of 1993. Same question of law in both the references has been referred for our opinion. The question reads as under: "whether, on the facts and in the circumstances of the case and on a correct interpretation of the relevant Rules for the allowance of extra shift allowance under the Income Tax Rules, 1962, the Tribunal was Justifies in law in holding that data processing machine, central air conditioning plant and air-conditioners are entitled to extra shift allowance though the works NESA (no extra shift allowance) are inscribed against such of the above Machinery or Plant in the said Rules?" ( 2 ) UNDER Rule 5 of the Income-Tax Rules 1962 an assessee is entitled to claim depreciation allowance in respect of depreciation of buildings, machinery, plant or furniture as may be included at the percentages specified in the second column of the table in part I of appendix I to 1962 Rules on the actual cost or, as the case may be, the written down value of such assets aforesaid for the purposes of the business or profession of the assessee at any time during the previous year, Since part I of appendix I to the Rules has been made the basis of claiming depreciation in terms of Rule 5 of 1962 Rules, we have to refer to this said part I of appendix I to determine and find out as to whether the assessee is entitled to claim extra-shift-allowance on data processing machines, central air-conditioning plants and the air-conditioners. Before we do that it shall be advantageous to refer to clause IV occurring in Part I of appendix I to 1962 Rules. This clause deals with and relates to the provision for extra-shift depreciation allowance and says that an extra-shift-allowance upto a maximum of an amount equal to one half of the normal allowance shall be allowed where a concern claims such allowance on account of double shift working and establishes that it has worked double shift. Various other stipulations are contained in clause IV relating to the provision and grant of extra-shift-depreciation allowance. While prescribing for the provision and grant of extra-shift depreciation allowance. Various other stipulations are contained in clause IV relating to the provision and grant of extra-shift-depreciation allowance. While prescribing for the provision and grant of extra-shift depreciation allowance. clause IV Itself clearly stipulates that the extra-shift allowance shall net be allowed in respect of any item of machinery or plant which has been specifically excepted by inscription of the letters NESA against such air item occurring III Part I of appendix I and also in respect of item, of machinery mentioned therein. Relevant extract of the illustration forming part of clause IV in part I of appendix I may be reproduced to indicate the clear intention about the disallowance and non-provision of the extra-shift-allowance. The extract reads as under: 'the extra Shift allowance shall not be allowed in respect of any item of machinery or plant which has been specifically by inscription of the letters 'n. E. S. A.- (meaning -no extra shift allowance) against it in sub-item Oil above and also in respect of the following items of machinery and plant to which the general rare of depreciation of 10% applies : ( 3 ) WHILE going through various items contained in part I we find that against the items of data processing machines, air-condition machines and air-conditioners, the inscription NESA has been written and inscribed. The fact that the inscription NESA has been inscribed against the aforesaid three items occurring in part I of appendix 1. The Intention of the legislature is very clear that even though extra-shift-allowance is allowable for same Items of plant and machinery where a concern claims such allowance on account of double shift working etc. etc. , such allowance has been specifically disallowed in respect of such plants and machinery, despite the aforesaid claim of the assesses being entitled to if the inscription NESA is found incorporated and mentioned against the relevant entry relating to such plant and machinery in part of appendix I. If we read Rule 5 of 1962 Rules we find that the allowance of depreciation has to be calculated at the percentage specified in the second column of the Table in part I of appendix I to the Rules and in accordance with the previsions contained herein. A combined reading of Rule 5 with Clause IV in part I of appendix I and the second illustration (supra) contained in clause IV, clearly suggests that there is no ambiguity about the intention of the Legislature in not granting and allowing extra-shift-allowance in respect of the items of plant and machinery mentioned in part I against which the inscription NESA finds a place. ( 4 ) IT is a well-established principle of law that a specific provision overrides a general provision. Whereas clause IV (supra) providing for the grant of extra-shift allowance is a general prevision, the illustration forming an integral part of the same clause is a special and specific prevision which prohibits and debars the grant of extra-shift-allowance in respect of some specified item, of plant and machinery against whose names the inscription NESA is found mentioned in the Table. In other words it can be also said that the legislature took away the concession of the grant of extra-shift-allowance in clause IV itself by expressly and specifically excluding certain items of plant and machinery, even while it allowed this concession to certain other items. Thus reading the two together, i. e. the illustration and clause IV, we find that there is neither any ambiguity nor any uncertaintity in interpreting this intention of the legislature. When therefore the intention of the legislator is very clear and, when there is no doubt in gathering such an intention by a clear and unambiguous reading of the provisions of low, importing extraneous considerations of giving reasons which are not wholly germane to the points involved is not permissible under law. We have very carefully gone through the judgment and other of the Income Tax appellate tribunal passed on 26th April. 1991 in I. T. R. No. 2004 and 2005 of 1989 relating to assessment years 1984-85, 85-86 and 86-87 and find that the reasoning given by the Tribunal for allowance extra-shift-allowance, in respect of data processing machines, air-conditioners and air-condition plants is wholly erroneous and patently contrary to the Income-Tax Rules 1962. Merely saying that these machines and appliances are and parcel of the plant and machinery and that extra-shift allowance is allowable on the plant and machinery cannot be a ground for allowance extra-shift-allowance because legislator has clearly prohibited such allowance by incorporating the inscription NESA against each of these items. Merely saying that these machines and appliances are and parcel of the plant and machinery and that extra-shift allowance is allowable on the plant and machinery cannot be a ground for allowance extra-shift-allowance because legislator has clearly prohibited such allowance by incorporating the inscription NESA against each of these items. No one can be allowed to go beyond express provisions of law, if law on a particular subject is clear and unambiguous. No one can import any reasoning, however sound it may appear which is contrary to the express provisions of law. in the present case the law is absolutely clear and totally unambiguous. Even while it provides for the grant of extra shift allowance in respect of the certain items of plant and machinery, at the same time it also clearly stipulates that in respect of some specified items of plant and machinery such allowance cannot be given. It is not understandable as to how the Tribunal ignored the inscription NESA and by importing its own reasoning allowed extra-shift allowance in favour or the assessee. ( 5 ) FOR the foregoing reasons therefore we answer the question in the negative, in favour of the revenue and against the assessees in both the references. Our opinion may be transmitted to the Tribunal for appropriate action. There shall be no order as to costs. V. N. Khare. C. J.- I agree. .