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of The HC allowed the revenue's appeal, set aside the impugned judgment and restored the matter for factual determination by the income-tax authorities. The court held that lower appellate fora (CIT(A) and ITAT) had adjudicated only the quantum of depreciation but had not addressed the pivotal factual question whether the respondent was the owner of the drilling ship. Ownership was characterized as a question of fact best resolved by authorities under the Income-tax Act, and the Single Judge's interference on that factual issue was held to be unjustified. Consequential directions were that entitlement to depreciation be determined afresh by the appropriate tax authorities.
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