- (1.) This appeal relates to the assessment year 1986-87.
(2.) The issue pertains to depreciation on the 1250 gas cylinders which the Assessee had claimed in that year, and which has been disallowed by the authorities below.
(3.) The brief facts which require mention for the purpose of the present appeal are as under: The Appellant-Assessee had set up its unit some time in September, 1985 to carry on the business of manufacturing and Compressing Oxygen, Hydrogen, Nitrogen Ammonia, Carbonic Acid, Action (including dissolved) Argon, cooking gas and other types of industrial gases or kind substances etc. For running the aforesaid plant, the Assessee had also bought 1250 gas cylinders. However, since the unit had not started functioning, these gas cylinders were leased out to M/s. Saraveshwari Gases (P) Limited, Ghaziabad and M/s. Malik Industries. In the return filed by the Assessee, he claimed depreciation on those gas cylinders at the rate of 100 per cent, as provided under the rules on the aforesaid item.;