Judgment :- S. Sankarasubban, J. This ITR is at the instance of the Revenue. The question of law referred to is as follows: "Whether, on the facts and circumstances of the case, the Tribunal is right in law and fact in holding that the assessee is entitled to depreciation at the rate of 15% on the furniture and fittings in the hospital on the view that hospital comes within the term "welfare centre" as appearing in appendix- I, Part I(ii) of the Income Tax Rules?" 2. The assessee is a partnership Firm, running a hospital and nursing home at Quilon. In the income-tax assessment for the year 1988-89, the assessee was allowed depreciation on furniture and fittings at 15%. The Commissioner of Income Tax later passed 'an order under S.263 of the Income Tax Act on the view that granting depreciation at 15% was not in order and that the correct rate of depreciation was 10% only. Accordingly, he directed the Assessing Officer to revise the assessment to restrict the allowance of depreciation at 10%. The assessee took up the matter in appeal before the Tribunal. The Tribunal held as follows: "As per appendix- I, Part I (ii) of the I.T. Rules, depreciation at the rate of 15% is allowable on furniture and fittings used in hotels, restaurants, schools, colleges and other educational institutions, welfare centres etc. According to the assessee, hospital is a welfare centre and so in respect of the furniture and fittings used in the hospital, depreciation is allowable at the rate of 15%. The expression "welfare centre" is not defined in the Income Tax Act or Rules. Hence, we have to give to the term "welfare centre" the meaning as commonly understood. If we attribute to the term "welfare" the meaning of enjoyment of health, improving the conditions of living as appearing in the dictionary, it is not difficult to see that a hospital qualifies as a welfare centre". Thus, the Tribunal held that hospital is welfare centre and hence is entitled to depreciation at 15%. 3. Under appendix- I, Part II(i), the rate applicable to furniture and fittings not covered by sub item (2) is 10%. Thus, the Tribunal held that hospital is welfare centre and hence is entitled to depreciation at 15%. 3. Under appendix- I, Part II(i), the rate applicable to furniture and fittings not covered by sub item (2) is 10%. For Item (2), furniture and fittings used in hotels, restaurants and boarding houses; schools, colleges and other educational institutions; libraries; welfare centres; meeting halls; cinema houses; theatres and circuses; and furniture and fittings let out on hire for use on the occasion of marriages and similar functions, the depreciation allowance is 15%. According to the Tribunal, a hospital will come within the meaning of "welfare centre". According to us, the interpretation given by the Tribunal is not correct. It is one of the principles of interpretation in the Taxation Law that the words of ordinary use should be given the meaning which is given by common people. Hospital is a place where sick is taken care of. When a person is taken to a hospital, nobody will say that he is taken to a welfare centre. Welfare centre is the centre for the wellbeing of the community. Hence, hospital will not come under item (ii). If that be so, only 10% depreciation is available. Hence, we answer the question in negative and against the assessee.