Judgment :- R. JAYASIMHA BABU, J. The following questions have been referred to us for our consideration and decision, at the instance of the Revenue, "1. Whether, on the facts and in the circumstances of the case and having regard to the provision contained in s. 32A(2)(b)(ii), the Tribunal is right in law in holding that the assessee-company is entitled for the investment allowance on welding set, car washer and platform scale ? 2. Whether, on the facts and in the circumstances of the case and having regard to the provision contained in s. 32A(2)(b)(ii), the Tribunal is right in law in holding that the assessee-company is entitled for the investment allowance on electric motor and platform scale ? 3. Whether, on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the expenditure incurred in connection with black-topping and contribution to the cost of improvement and development should be regarded as revenue expenditure ?" These questions arise out of the assessment of the respondent, Tamil Nadu Magnesite Ltd., Salem, for the asst. yrs. 1981-82, 1982-83 and 1983-84 respectively. 2. The first two questions concern the assessee's right to claim investment allowance on welding set, car washer platform scale and electric motor. 3. The third question referred to us with regard to the character of expenditure incurred on black-topping and contribution to the cost of investment and development. In the statement of claim, it is stated that the expenditure on the road was incurred to facilitate easy movement of and to reduce wear and tear of the vehicles used by the company in its mining operations. Such expenditure has been held in the case of L. H. Sugar & Oil Mills (P) Ltd. vs. CIT, as business expenditure. It was held therein that the contribution made towards a part of the cost of construction of roads in the area around factory is wholly and exclusively laid out for business and does not constitute capital expenditure. The assessee is, therefore, entitled to deduction of the contribution to the cost of improvement and development of the public roads leading to the mines, contribution having been made to the Government which had incurred the balance of expenditure required for black-topping of roads and which resulted in a benefit to the business of the assessee. The assessee is, therefore, entitled to deduction of the contribution to the cost of improvement and development of the public roads leading to the mines, contribution having been made to the Government which had incurred the balance of expenditure required for black-topping of roads and which resulted in a benefit to the business of the assessee. The third question is, therefore, answered in favour of the assessee and against the Revenue. 4. As regards the first two questions, it was submitted for the Revenue that there is no direct access (sic-nexus) between the mining operation of the assessee and the items of machinery in respect of which allowance has been claimed. Counsel relied upon the judgment of the Calcutta High Court in the case of CIT vs. Machinery Mfg. Corpn. Ltd., wherein it was held that each and every item of machinery and plant is not eligible for investment allowance even though it may be used in the business and further that such machinery or plant must have a close nexus with the business of construction, manufacture or production of any article or thing, not being article or thing as provided for in s. 32A of the IT Act, 1961. 5. Counsel for the assessee, on the other hand, submitted that s. 32A 2(b) speaks of the business of construction, manufacture or production of any article or thing and the term 'business' in the context is a term having wider connotation than the process of manufacture or mining. 6. This matter was adjourned at this stage in order to enable the assessee's counsel to provide adequate clarifications with regard to the nature of the activity carried on by the assessee and the methods employed in order to have a clearer picture of the nature and scope of the business carried on by it. We regret to record that the assessee's counsel has failed to place any material, though time had been granted specifically for that purpose. It is disappointing to note that invariably the assessee failed to place the material required for conveying a full picture of the true state of affairs concerning the matters required to be examined by the Court. It is hoped that, in future at least this situation would be remedied. 7. It is disappointing to note that invariably the assessee failed to place the material required for conveying a full picture of the true state of affairs concerning the matters required to be examined by the Court. It is hoped that, in future at least this situation would be remedied. 7. The authorities below have proceeded on the basis that the assessee, which is engaged in the business of mining magnesite is entitled to investment allowance. As to whether that view is correct or is not correct is not the issue before us. The ITO has denied the benefit of investment allowance to platform scales, welding sets, electric motors and car washers owned by the assessee and used in its business on the ground that the use of these items of machinery had no direct nexus with the business that was being carried on by the assessee. 8. The CIT(A) as also the Tribunal have, in our view, rightly held that the view adopted by the ITO was too narrow, having regard to the language of the section. We are inclined to agree what the Tribunal has held with regard to welding sets, platform scales and electric motors, as all these items have a reasonable nexus with the business that is carried on by the assessee. The use of electric motors is necessary for running the machinery and it is not possible to record electric motors as a separate item without the aid of which machinery can (sic-cannot) be run. Platform scales are required for weighing the material that is mined whenever it is necessary to do so, and can be regarded as being reasonably necessary for the business carried on by the assessee. Welding set, though not directly usable in the extraction of mineral, may also be regarded as reasonably necessary, as it is not uncommon that machinery or implements which are required for use in the extraction of mineral may suffer damage and require welding which is best done immediately in the premises of the assessee in order to minimise the disruption in the mining activity. 9. We, however, do not see any justification for allowing investment allowance on car washers, as that cannot be regarded as reasonably necessary for the business that is carried on by the assessee. 10. 9. We, however, do not see any justification for allowing investment allowance on car washers, as that cannot be regarded as reasonably necessary for the business that is carried on by the assessee. 10. The language employed in s. 32A(2)(b)(ii) of the Act is such as to require a consideration of the business requirements of the assessee so long as that business of the assessee relates to construction, manufacture or production. The investment allowance, therefore, is not to be confined only to the plant and machinery actually deployed in construction, manufacture or production. The allowance may be claimed in respect of plant and machinery which are reasonably required for the business, though not directly deployed in the construction, manufacture or production. 11. The question referred to us arising out of the assessment of the respondent's income for the asst. yrs. 1981-82 and 1982-83 are, therefore, answered in favour of the assessee, and against the Revenue. In the circumstances of the case, there will be no order as to costs.