Dismissing the appeal the Court held that the first appellate authority had specifically found that the claim was not decipherable even from the accounts, since the profit and loss account did not show the expenditure towards the leased equipment. For not having raised the claim, the explanation was that under the Companies Act, the depreciation on both assets and owned by the assessee and leased assets could be claimed, while under the Income-tax Act, depreciation claim was permissible only on assets owned by the assessee. However, the assessee was quite conscious of the fact that there could be no depreciation claimed on leased assets under the Act since no such claim was made in the returns filed. Hence, the claim not having been raised could not be said to be a bona fide omission. The depreciation having not been specifically claimed in respect of leased assets, the assessee was entitled to claim business expenditure, of the lease rent, which it had not claimed in the return. There was no such expenditure shown in the profit and loss account. The rejection of the claim was justified.