JUDGMENT judgment of court was delivered by R. Sudhakar J.-The above tax case (appeals) are filed by Revenue as against order dated June 26, 2014, made in I. T. A. Nos. 154 and 155/ Mds/2014 on file of Income-tax Appellate Tribunal, Madras "B" Bench, for assessment years 2005-06 and 2006-07 raising following substantial question of law: "Whether, on facts and in circumstances of case, Tribunal was right in holding that generation of electricity by windmill amounts to production of article or thing and, consequently, holding that assessee is entitled for additional depreciation as per section 32(1)(iia)?" brief facts of case in nut-shell are as follows: assessee is partnership firm engaged in business of textiles and generation and distribution of power. assessee filed return of income claiming additional depreciation on windmill. Assessing Officer disallowed assessee's claim of additional depreciation on windmill under section 32(1)(iia) of Income-tax Act holding that assessee failed to satisfy one of condition, namely, assessee should be engaged in business of manufacture and production of article or thing. Assessing Officer further held that production of electricity through windmill was not production of article or thing. Aggrieved by same, assessee preferred appeal before Commissioner of Income-tax (Appeals), who, by following decisions of this court in case of CIT v. VTM Ltd. and CIT v. Hi Tech Arai Ltd. allowed appeal. As against same, Revenue preferred appeal before Incometax Appellate Tribunal, which dismissed appeal following decision of this court in case of CIT v. VTM Ltd. It is stated by Tribunal that as against said decision of this court, Revenue preferred appeal before Supreme Court and Supreme Court dismissed same in special leave petition stage itself. Hence, Tribunal held that no material has been brought on record to show that said decision of this court in case of CIT v. VTM Ltd. has been either modified or reversed by Supreme Court. Aggrieved by said order of Tribunal, Revenue is before this court. Heard learned standing counsel appearing for Revenue and perused materials placed before this court. In decision reported in CIT v. Hi Tech Arai Ltd. [2010] 321 ITR 477 (Mad), this court, while considering scope and application of section 32(1)(iia) of Income-tax Act held as follows (page 480): "As far as application of section 32(1)(iia) of Act is concerned, what is required to be satisfied in order to claim additional depreciation is that setting up of new machinery or plant should have been acquired and installed after March 31, 2002, by assessee, who was already engaged in business of manufacture or production of any article or thing. said provision does not state that setting up of new machinery or plant, which was acquired and installed up to March 31, 2002, should have any operational connectivity to article or thing that was already being manufactured by assessee. Therefore, contention that setting up of windmill has nothing to do with power industry, namely, manufacture of oil seeds, etc., is totally not germane to specific provision contained in section 32(1)(iia) of Act. In such circumstances, we are not able to appreciate contention of learned standing counsel for appellant on ground that order of Commissioner of Income-tax (Appeals) as confirmed by Tribunal should be interfered with. It cannot also be said that setting up of windmill will not fall within expression setting up of new machinery or plant. We do not find any error in conclusion of Tribunal in confirming order of Commissioner of Income-tax (Appeals). We, therefore, do not find any question of law much less substantial question of law to entertain these appeals. These appeals fail and same are dismissed. Consequently, M. P. No. 1 of 2009 is also dismissed." facts in present case are no different from abovesaid decision. In present case, core business of assessee is manufacturing and export of textile goods. During assessment year 2006-07, assessee had entered into business of generation of power and installed one windmill. assessee maintained separate books of account for export division and windmill division. Since assessee has treated windmill division as separate business, claim of additional depreciation has to be seen in context of generation of power through windmill only and production of textiles and its export has nothing to do with generation of power for purpose of considering additional depreciation. Further, as rightly held by Tribunal, Revenue has not brought in any new or contra material to differ from view of this court in decision reported in CIT v. Hi Tech Arai Ltd. [2010] 321 ITR 477 (Mad). Accordingly, following abovesaid decision of this court, we find no infirmity in order passed by Tribunal. We, therefore, do not find any question of law much less substantial question of law to entertain these appeals. In result, both tax case (appeals) stand dismissed. No costs. Consequently, M. P. No. 1 of 2015 is closed. *** Commissioner of Income-tax v. Atlas Export Enterprise