The assessee, engaged in laying petroleum pipelines, claimed depreciation including liability of Rs. 20 crores payable to KPT and GMB. AO disallowed Rs. 5 crores depreciation, holding the liability contingent. CIT(A) and Tribunal upheld disallowance. Dismissing appeal, the High Court held that no contractual payment was made, nor liability accepted by port authorities; hence it was only a contingent liability. Findings being concurrent factual findings, no substantial question of law arose.(AY.2003-04)