The Tribunal held that the consideration paid by the assessee could reasonably include not only the cost of construction of the building but also the cost of proportionate land. This sub-lease specifically provides that the four units were allotted to the assessee together with the proportionate land, that the nominal yearly ground rental of Re. 1 charged to the assessee was at a concessional rate in order to promote export industries in India. The agreement should be read as a whole and the consideration paid by the assessee was not only for the cost of construction of the four units but the same also included cost of proportionate land. To this extent, there was no infirmity in the order passed by the Commissioner (Appeals).      It was further held that the Commissioner (Appeals) has placed reliance on the stamp duty rate of proportionate land during the relevant period of acquisition of the four units, which was quite reasonable, as only about 35 per cent. of the consideration was treated as a cost of proportionate land. There was no infirmity in the order passed by the Commissioner (Appeals) granting partial depreciation to an extent of Rs. 48,17,491 as against Rs. 65,61,664 claimed by the assessee. (AY. 2010-11, 2011-12)