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The High Court of Allahabad ruled in favor of the assessee, a private limited company, allowing depreciation on capital expenditure for improving leased buildings during assessment years 1969-70 to 1971-72. The Tribunal held that the improvements belonged to the assessee for the duration of the lease, making them eligible for depreciation under section 32(1) of the Act. The court supported this decision based on the business purpose of the improvements and previous case law. The question of law was answered in favor of the assessee, who was awarded costs of Rs. 200.
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