COMMISSIONER OF INCOME-TAX(CENTRAL) vs M/S. GWALIOR RAYON SILK MFG.(WVG.)CO.LTD

The Supreme Court held that roads constructed within factory premises are to be treated as 'buildings' for the purposes of depreciation under Section 32 of the Income Tax Act, 1961. The Court emphasized that the interpretation of taxing statutes should favor the assessee, and that the term 'building' should encompass necessary adjuncts like roads for the effective operation of a factory. The Court upheld the Tribunal's decision allowing depreciation on roads, thereby affirming the principle that statutory interpretations should align with practical business needs.