On appeal, the Commissioner (Appeals) held that profits disclosed were subject to adjustment and depreciation as granted in accordance with the rates prescribed under the Act and therefore, the accumulated profits were to be computed taking into account the depreciation as per the Income-tax Rules. Tribunal allowed the appeal of the Revenue. On appeal High Court set aside the order of the Tribunal and held that profits disclosed would be subject to adjustment and depreciation as granted in accordance with rates prescribed by Income-tax Act  have to be deducted for ascertaining accumulated profits. (AY. 2000-01)