The Tribunal held that the assessee failed to establish that the dominant purpose was to use the vehicles for running them on hire. The dominant purpose was to use the vehicles for its own business. The purpose of allowing deduction at higher rate of depreciation in vehicles running them on hire was that the vehicles were used extensively without taking much care and suffer heavy wear and tear. Whereas in the case of the assessee’s business, the wear and tear was lesser than the vehicles used in running on hire. In the instant case, the assessee also failed to establish that the vehicles were used in the business of running them on hire. Therefore the assessee was disentitled for higher rate of depreciation. (AY.2011-12 to 2015-16).