Judgment :- P. THANGAVEL, J. At the instance of the Revenue, the following question of law is referred for the opinion of this Court under s. 256(1) of the IT Act, 1961: "Whether the Tribunal's finding that electrical transformers should be treated as textile processing machinery and allowed extra shift allowance is sustainable in law in view of the prohibition contained in the rules ?" 2. The assessee was using electrical transformers for the working of textile processing machinery. The ITO of the concerned circle has decided that as per IT Rules, 1962, Appendix-I, transformers are not eligible for extra shift allowance. But, the CIT(A) was of the opinion that electrical transformers should be considered as integral parts of the abovesaid textile processing machinery and, therefore, the electrical transformers are eligible for extra shift allowance. According to the Revenue, the Appendix to r. 5 sets out the rates of depreciation on different items of assets and according to it, extra shift allowance will not be available in respect of any item of machinery or plant specifically excepted by inscription of the letter N.E.S.A. The Revenue has also relied on item No. 5, under which electrical machinery was described as switchgear and instruments, transformers and other stationary plant and wiring and fittings of electric lights and fan installations. The Tribunal negatived the abovesaid contention of the Revenue and upheld the claim made by the assessee, holding that electrical transformers are eligible for extra shift allowance. While holding so, the Tribunal has held that electrical transformers are integral part of the textile processing machinery and that the Appendix sets out various items of machinery and in respect of each category, there are items of plant and machinery, which bear the inscription N.E.S.A., thereby meaning that they are ineligible for extra shift allowance. The Tribunal has also held that a reading of various items listed out in the Appendix would disclose that extra shift allowance is not allowed in respect of machineries, to which special rates like 20 per cent to 30 per cent apply, but the machineries, in respect of which general rate is applicable, are eligible for extra shift allowance. The Tribunal has also held that a reading of various items listed out in the Appendix would disclose that extra shift allowance is not allowed in respect of machineries, to which special rates like 20 per cent to 30 per cent apply, but the machineries, in respect of which general rate is applicable, are eligible for extra shift allowance. The Tribunal has also come to the conclusion, after considering the representation made on the side of the Revenue, that the prohibition contained in granting extra shift allowance would apply only to machineries, which are independent machineries by themselves and not to machineries forming part and parcel of other types of machineries which are entitled to extra shift allowance. 3. Aggrieved at the order of the Tribunal, at the instance of the Revenue the question of law set out above has been referred for the opinion of this Court. 4. The assessee is carrying on textiles processing business at Komarapalayam by using textile processing machineries in the mill premises. The fact remains that electrical transformers are installed within the abovesaid premises and Electricity Board is supplying energy through high tension lines to the abovesaid transformers, from where electricity is supplied for the abovesaid textile processing mill to run its machineries. It is for the abovesaid transformers, extra shift allowance is claimed by the assessee, which was upheld by the Tribunal as referred to above. 5. Learned counsel for the Revenue would contend that the electrical transformers installed in the textile processing mill of the assessee could not be considered as an integral part of the textile processing machinery of the assessee, that the electrical transformers are independent instruments by themselves, that the abovesaid item will fall within the meaning of items excepted by inscription of letters N.E.S.A. (no extra shift allowance), to which general rate of depreciation of 10 per cent applies and, therefore, extra shift allowance cannot be given to electrical transformers as held by the Tribunal. Learned counsel for the assessee contended contra to the above said contentions, to sustain the conclusion of the Tribunal. 6. We have considered the rival submissions made by both the sides in depth in the light of the materials available on record. Learned counsel for the assessee contended contra to the above said contentions, to sustain the conclusion of the Tribunal. 6. We have considered the rival submissions made by both the sides in depth in the light of the materials available on record. It is evident from Appendix I to the IT Rules, 1962, that extra shift allowance shall not be allowed in respect of any item of machinery or plant, which has been specifically excepted by inscription of letters N.E.S.A. against the machinery and plant to which general rate of depreciation of 10 per cent applies. In excepted items with heading "electrical machinery" switchgear and instruments, transformers and other stationary plant and wiring and fittings of electric light and fan installations are described along with other items. Therefore, it is evident that electrical transformers will come within the excepted item to which general rate of depreciation of 10 per cent is applicable. 7. Electric transformers are admittedly used to receive electric energy from high tension lines supplied by the Electricity Board and from the abovesaid electrical transformers, the electric supply is made to the plant or machinery, in order to run the same. It is also relevant to point out that the quantum of electricity consumed by the plant or machinery will be metered only at the place where the transformers are erected by the Electricity Board to collect necessary charges for such consumption of electricity. The electrical transformers, even if they are in the premises of the assessee, will be under the control and supervision of Electricity Board. The fact of supplying energy from the transformers to the assessee's plant or machineries will not go to mean that the abovesaid electrical transformers will form integral part of the textile processing machinery, run by the assessee. It is a separate item, used to receive energy from the high tension line. In view of that fact, the conclusion arrived at by the Tribunal that the electrical transformers in dispute will form integral part of the textile processing machinery of the assessee, cannot be accepted. 8. Learned counsel for the Revenue has brought to out notice the decision in CIT vs. Kiran Crimpers 1997 (220) ITR 84 (Guj) : TC S27.2807. In view of that fact, the conclusion arrived at by the Tribunal that the electrical transformers in dispute will form integral part of the textile processing machinery of the assessee, cannot be accepted. 8. Learned counsel for the Revenue has brought to out notice the decision in CIT vs. Kiran Crimpers 1997 (220) ITR 84 (Guj) : TC S27.2807. In that case, it was held that in the first instance the rate of general depreciation has to be prescribed under sub-items (i) and (ii) of item III of Part I of Appendix I to the IT Rules, 1962, thereafter when the question of extra shift allowance arises to be considered under sub-item (iv), it has to be seen what specific items have been excluded from the applicability of extra shift allowance and if any items have been specifically so excluded either by inscribing N.E.S.A., while including that item under the description of machinery and plant slated for the special rate or the general rate, such item cannot be made available for computation of extra shift allowance. It has also been held that once an apparatus becomes an integral part of another asset as such, it loses its independent identity as an asset and the asset of which it becomes an integral part alone is to be considered as an asset, that in other words, unless one apparatus which independently is a plant or machine, when fitted to another machine to make that machine complete, becomes an integral part of the concerned asset itself and loses its independent identity, it cannot be said that the two assets are one, but mere interdependency upon each other for their functioning does not make the two assets one for the purpose of claiming depreciation. Further, it has also been held that it is a well-known principle of interpretation that where there are two entries covering the same item, one special and another general, the applicability of the general provision shall be excluded. 9. Further, it has also been held that it is a well-known principle of interpretation that where there are two entries covering the same item, one special and another general, the applicability of the general provision shall be excluded. 9. In the light of the observations made above it was held in that case that the phrase used in entry (2) of sub-item (ii) B of item III of Part I of Appendix I to the Rules is air-conditioning machinery including room air-conditioners, that this goes to show that this entry deals with all types of air-conditioning machinery whether used in a room, factory or office or any other place of business irrespective of any particular use to which it is put and that, therefore, no extra shift depreciation allowance is allowable in the case of air-conditioners necessarily used for crimping nylon yarn. 10. It has already been held that the electrical transformers are independent items and they will not form integral part of the textile processing machinery of the assessee, except to transmit energy from the transformers through cables to the abovesaid textile processing machineries of the assessee. It is also evident as mentioned above, that electrical transformers are entitled to depreciation allowance at 10 per cent under the general category rate. If the principles laid down in the case cited above are applied by way of analogy to the facts and circumstances of this case, in the light of Appendix I to IT Rules, 1962, it is quite clear that extra shift allowance cannot be granted to the demised electrical transformers installed in the premises of the assessee. Therefore, we accept the arguments advanced by learned counsel for the Revenue. 11. According we answer the question of law referred to this Court in the negative and in favour of the Revenue. In the circumstances of the case, there will be no order as to costs.