The assessee was a trust registered under section 12A of the Income-tax Act, 1961. The trust was running a residential school. The assessee provided transport facility in the form of school buses for attending the school, picking up and dropping both students and teachers. The assessee claimed additional depreciation for the school buses operated by the assessee. The claim was rejected by the Assessing Officer, the Commissioner (Appeals) and the Tribunal. On appeal to the High Court held that the assessee trust was not entitled to additional depreciation on the buses.