Sen, J. - (1.) The proceedings arise out of the claim of Messrs. Dehri Rohtas Light Railway Co., a railway company, for depreciation on its locomotives and rolling stock at the rate of 10% and also for extra shift allowance in respect thereof, in its assessments to income-tax for the assessment years 1963-64 and 1964-65, the corresponding previous years being the financial years 1962-63 and 1963-64. The assessee contended that its rolling stocks and locomotives were being used for 24 hours every day. The ITO disallowed the claim of the assessee.
(2.) Being aggrieved, the assessee preferred appeals to the AAC and succeeded therein. The AAC directed the ITO to recompute the chargeable profits after allowing extra shift allowance as claimed.
(3.) The revenue being aggrieved preferred further appeals to the Tribunal. The Tribunal did not accept the contentions of the revenue and confirmed the orders of the AAC. The appeals were dismissed.;