Tribunal is justified in allowing the depreciation at 10% in roads.  Court also held that the land on which the facility had been developed by the assessee, was owned by the SIPCOT and the development consisted of providing roads inside the IT Park, establishment of a multi-level car parking, etc. Under the agreement, the assessee had to develop these facilities and maintain them and the period was stated to be 99 years, which is virtually perpetual. Therefore, a deeper examination of the factual issue was warranted. The matter had to be readjudicated by the Assessing Officer, for which purpose, the Assessing Officer had to analyse the agreement dated September 21, 2005 entered into between the assessee and the SIPCOT and not go merely by the nomenclature.(AY. 2007-08 to 2010-11, 2012-13 and 2013-14)