( 1 ) THE question submitted by the Revenue seeking to call for a reference from the Tribunal is whether the Tribunal has been right to hold the deduction allowable under section 32 of the Income-tax Act to the assessee on the purchase of the bottles which it leased out as a business. The submission of Mr. S. R. Ashok, learned counsel for the petitioner, is that even if for the purpose of the business of the respondent the bottles are treated as "plant" within the meaning of section 32 (1), yet the deduction is allowable only when the purchase is en bloc and cannot be allowed in respect of single bottles which would obviously be priced less than Rs. 5,000. The Tribunal placed reliance on the decision of this court in CIT v. Sri Krishna Bottlers Pvt. Ltd. [1989] 175 ITR 154, to hold bottles as "plant" and 100 per cent. depreciation could be available.

( 2 ) THE impugned assessment is of the year 1985-86. Section 32 (1) is in the following terms :"32. Depreciation.- (1) In respect of depreciation of buildings, machinery, plant or furniture owned by the assessee and used for the purpose of the business or profession, the following deductions shall, subject to the provisions of section

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