Dismissing the appeal of the revenue the Court held that ,  the Tribunal had found on the facts that the reduction of loss was on account of the disallowance of the depreciation claimed by the assessee. It had also found that the disallowance was on the dispute of the machinery not having been installed during the assessment year, and such depreciation was available to the assessee in later years. Since there was consistent loss offered by the assessee, such shifting of the depreciation to a later year had no impact on its tax. (AY.1991-92)