Held that the assessee was eligible for depreciation under Explanation 1 of the proviso to section 32 of the Act but the Assessing Officer was to verify whether the amount of addition had been capitalized, and then allow the depreciation. That the assessee was running a resort and it being a tourist place, the occupancy was not throughout the year but only in seasons favourable to tourists. Therefore, it could not be construed that the asset was used for less than 180 days. The Assessing Officer was to allow depreciation for entire year. (AY.2011-12)