JUDGMENT judgment of court was delivered by R. Sudhakar J.-Aggrieved by order of Tribunal in dismissing appeal filed by it, assessee-appellant is before this court by filing present appeal. This court, vide order dated February 9, 2008, while admitting appeal, framed following substantial questions of law for consideration: "(i) Whether, on facts and in circumstances of case, Tribunal was justified in treating expenditure on replacement of plant and machinery as capital in nature? (ii) Whether, on facts and in circumstances of case, Tribunal is correct in not allowing depreciation at 100 per cent. on specified items?" facts, in nut-shell, are as hereunder: appellant is in business of manufacture of automobile components. In respect of replacement of plant and machinery, which is part of continuous manufacturing system, appellant claimed sum of Rs. 71,07,022 as revenue expenditure and further claimed 100 per cent. depreciation on certain items on ground that all items are energy saving devices. Assessing Officer, however, held against assesseeappellant, against which appellant moved Commissioner of Income-tax (Appeals), who on consideration of matter, allowed appeal in part. Aggrieved against said portion of order, which went against it, appellant-assessee preferred appeal to Tribunal, which was dismissed, confirming order of Commissioner of Income-tax (Appeals), against which present appeal has been filed. Heard learned counsel appearing for appellant-assessee and learned standing counsel appearing for respondent-Department and perused materials available on record as also orders passed by authorities below. In so far as second substantial question of law is concerned, we find that it is mostly in nature of facts as to whether certain equipment are entitled to 100 per cent. depreciation. To be more clear on this aspect, relevant portion of order of original authority dated March 27, 2001, relating to equipment is extracted hereinbelow for better clarity: "3. At time of hearing assessee also claimed that equipment to extent of Rs. 20,63,694 were entitled to 100 per cent. depreciation as they were energy saving/air/water pollution control equipment. It was pointed out that except for claim at this late stage in March what other proof they could produce to identify such equipment were energy saving equipment and listed in Appendix I of rule 5. This claim was not made while filing return of income, nor while filing details. Suddenly, assessee-company comes in March and claims that this equipment is also eligible for 100 per cent. depreciation. assessee has no convincing support to sustain its claim. Many of items are entitled to normal depreciation only, which was claimed and allowed. Hence, this claim which was not reflected in annual report given to shareholders and Company Law Board is clearly afterthought with intention to avail of greater benefit. Moreover, names of purchase invoices differ from what assessee claims to have entitled for 100 per cent. depreciation. So same is rejected. assessee pursued matter in appeal and Commissioner of Income-tax (Appeals), vide order dated June 24, 2004, justified disallowance of 100 per cent. depreciation as and held as follows: "I have carefully considered Assessing Officer's observation as well as Appendix I relating to depreciation. I agree with observation made by Assessing Officer except for 2 items, viz., micro processor based pressure indicating system of Rs. 1,13,624 and voltage stabilizer Rs. 6,700. According to me, first is covered under item III(3)(iii)(B)(c) and second item is covered under item III (3)(iii)(E)(c). I, therefore, direct Assessing Officer to allow 100 per cent. depreciation to appellant only on these two items. Therefore, appellant partly succeeds on this ground." Tribunal, on appeal by assessee-appellant, held in favour of Revenue, affirming order of Commissioner of Income-tax (Appeals), relevant portion of which is extracted hereunder: "4. next issue raised pertains to claim of 100 per cent. depreciation on following assets: (a) Micro processor based carrier frequency amplifier; (b) Oil filtration systems; (c) Online sinewave UPS systems and battery for same; (d) Variable frequency drive. 4.1 On this issue, as regards item No. 4(1), lower authorities have given finding that machinery installed by assessee are not covered under item III(3)(B) of Table of depreciation rates. Similarly, as regards rest of items, finding has been given that they are not covered under item III(3)(E) of said table. 4.2 learned Departmental representative submitted that these findings of lower authorities are on firm footing and have not been controverted by assessee by any cogent explanation. 4.3 Upon careful consideration of issue, we are of considered opinion that learned Commissioner of Income-tax (Appeals) on this issue has taken correct view. Hence, we uphold his orders." It has been time and again held by Supreme Court in catena of decisions that concurrent findings of fact by lower authorities on factual issues should not be reappreciated on appeal, unless it is shown to be ex facie perverse. Supreme Court in Ghisalal v. Dhapubai [2011] 2 SCC 298 has held that unless findings are ex facie perverse, concurrent findings should not be interfered with. relevant portion of order is extracted hereunder: "The consideration of this issue deserves to be prefaced with observation that this court is extremely loath to interfere with concurrent finding of fact recorded by courts below more particularly when such finding has been approved by High Court. In such matters, interference is warranted only when this court is convinced that finding is ex facie perverse. finding of fact can be treated as perverse if it is based on no evidence or there is total misreading of pleadings and/or evidence of parties or finding is based on unfounded assumptions or conjectures." In yet another decision in Chandra Bihari Gautam v. State of Bihar [2002] 9 SCC 208, Supreme Court has held as under: "5.... Time and again it has been held by this court that no interference would be made with concurrent finding of fact based on pure appreciation of evidence even if this court was to take different view on evidence. court will normally not enter into reappraisal or review of evidence unless trial court or High Court is shown to have committed error of law or procedure and conclusions arrived at are perverse. This court cannot enter into credibility of evidence with view to substitute its opinion for that of High Court. This court may interfere where on proved facts wrong inferences of law are shown to have been drawn. It needs to be emphasised that this court is not regular court of appeal to which every judgment of High Court in criminal case may be brought up for scrutinising its correctness. It is only in rare or exceptional case where there is some manifest illegality or grave or serious irregularity that court would interfere with such findings of fact. In this regard reference may be made to judgments of this court in Duli Chand v. Delhi Admn. [1975] 4 SCC 649, Ramaniklal Gokaldas v. State of Gujarat [1976] 1 SCC 6, Dalbir Kaur v. State of Punjab [1976] 4 SCC 158 and Ramanbhai Naranbhai Patel v. State of Gujarat [2000] 1 SCC 358, etc." Keeping above position of law in mind, even cursory look at order passed by Tribunal would manifestly reveal that Tribunal, on issue of depreciation, after going through orders of lower authorities was of view that view taken by Commissioner of Income-tax (Appeals) is correct on facts. Such being factual scenario, in absence of any specific material on legal issue, disputing manner in which issue of depreciation was considered, we are not inclined to go into issues on facts as projected by appellant-assessee. Accordingly, second substantial question of law is answered in favour of Revenue and against assessee. In so far as first question of law is concerned, learned counsel appearing for appellant pleads that issue should be remanded back to Commissioner of Income-tax (Appeals) to consider whether replacement of plant and machinery would be case of revenue expenditure or capital expenditure. Similar issue, it appears, has been considered by this court in case of Super Spinning Mills Ltd. v. Asst. CIT [2013] 357 ITR 720 (Mad), wherein, this court, following decision of Supreme Court in CIT v. Sri Mangayarkarasi Mills P. Ltd. [2009] 315 ITR 114 (SC), remanded matter back to Commissioner of Income-tax (Appeals) for consideration and pass detailed orders. relevant portion is extracted hereinbelow for better clarity (page 730): "Even though assessee has furnished list of items chart, data which are available before us were not available before any of appellate authorities for coming to right conclusion herein. Thus, with no details available as stated in case of CIT v. Ramaraju Surgical Cotton Mills reported in [2007] 294 ITR 328 (SC), decision of Tribunal cannot be held as based on any material data necessary for considering claim one way or other. Hence, proper course herein is to set aside order of Income-tax Appellate Tribunal and remit matter back to Commissioner of Income-tax (Appeals) for de novo consideration. Keeping in view law declared by apex court in case of CIT v. Ramaraju Surgical Cotton Mills reported in [2007] 294 ITR 328 (SC) and in case of CIT v. Sri Mangayarkarasi Mills P. Ltd. reported in [2009] 315 ITR 114 (SC); [2009] TIOL-86-SC-II, Commissioner of Income-tax (Appeals) shall grant opportunity to assessee to state its case in proper perspective and decide on issue as to whether expenditure, in effect, could be treated as'revenue expenditure'. We direct Commissioner of Income-tax (Appeals) to pass detailed order on impact of replaced material as well as functioning of machinery after hearing assessee in detail, who, we hope, would extend all co-operation before Commissioner of Income-tax (Appeals) and furnish materials for arriving at proper conclusion. " Following abovesaid ratio, without going into first substantial question of law as raised above, this court is of considered opinion that matter has to be remanded back to Commissioner of Income-tax (Appeals) for reconsidering issue. Accordingly, on first issue, matter is remanded back to Commissioner of Income-tax (Appeals) for consideration and passing detailed orders. In result, appeal is partly allowed by way of remand. However, in circumstances of case, there shall be no order as to costs. *** Autolec Industries Ltd. v. Joint Commissioner of Income-tax