- (1.) LEARNED counsel for the respondents submitted that the issue raised by the appellant in this appeal as question of law in fact stands answered, in view of the judgment of Patna High Court delivered in the case of Commissioner of Income Tax Vs. Steel City Beverages (P) Ltd. reported in : (1996) 222 ITR 744 (Pat.). It is also submitted that the same issue has been considered by the Madras High Court in the case of Commissioner of Income Tax Vs. Upasna Finance Ltd. reported in : (2006) 286 ITR 179 (Mad.) and Andhra Pradesh High Court in the case of Commissioner of Income Tax Vs. Margdarshi Chit Fund (P) Ltd. and has been answered against the Revenue and it has been held that " the assessee would be entitled to depreciation on new purchases of the containers' and in present case also they are on the articles of Moulds which are also the containers. In view of the above decisions, we are of the considered opinion that the issue is covered by the judgment referred above and the Tax Appeal, therefore, is dismissed in the light of the reasons given in the above judgments.;