We have to consider the issue in purview of the relevant Acts,i.e, Income Tax Act and Companies Act. UPS is also a machine which like Generator and Inverter is similar in nature and functionality. The definition of computer has not been given in the Income Tax Act . As such its meaning is to be derived from the allied Acts. The definitions from the Information Technologies Act are given below:
computer" means electronic, magnetic, optical or other high-speed date processing device or system which performs logical, arithmetic and memory functions by manipulations of electronic, magnetic or optical impulses, and includes all input, output, processing, storage, computer software or communication facilities which are connected or relates to the computer in a computer system or computer network;

"computer network" means the inter-connection of one or more computers through-

(i) the use of satellite, microwave, terrestrial lime or other communication media; and

(ii) terminals or a complex consisting of two or more interconnected computers whether or not the interconnection is continuously maintained;

"computer resources" means computer, computer system, computer network, data, computer database or software;

"computer system" means a device or collection of devices, including input and output support devices and excluding calculators which are not programmable and capable being used in conjunction with external files which contain computer programmes, electronic instructions, input data and output data that performs logic, arithmetic, data storage and retrieval, communication control and other functions
From the above, it is clear that UPS is not covered in the definition of Computer or Computer System. In view of the above, it can only fall under the head of Plant and Machinery.

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