Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble
145 (Bombay) and argued that the assessee is only a licensor and does not own the property and 6 hence depreciation cannot be allowed on the Berths constructed by the assessee. The Ld. DR supported the order of the Ld. AO. Per contra, at the outset, the Learned Authorized Representative [Ld. AR] invoked the provisions of Rule