Judgment

Mrs. Sujata V. Manohar, J.-Delay condoned.

2. Leave granted.

3. These appeals raise a common question relating to the assessee’s entitlement to investment allowance under Section 32A of Income-tax Act, 1961. The assessee companies, as their names suggest, are finan­cial companies which purchase machinery and hire out the machinery to manufacturers under agreements of hire. The common question in these appeals relates to the entitlement of the assessees to investment allowance under Section 32A of the Income-tax Act, 1961. For the sake of convenience, we are setting out the question as framed in Civil Appeal Nos. 7077-78 of 1993. The question is as follows :

“Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that in respect of the machineries owned by the assessee, but leased to third parties and used by them for the manufacture of article or thing, investment allowance was allowable under Section 32A?”

4. The assessees are not themselves manufacturers of any article or thing. The machineries, however, which are owned by them are hired to different persons for the purpose of their business of manufacturing. In respect of these machiner