( 1 ) THE following questions are involved in this reference under Section 66 (2) of the Indian Income-tax Act, 1922 :"1. Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee was entitled to get depreciation allowance under Rule 8 of the Income-tax Rules even in respect of ships which had formed part of the assessee's fleet for more than twenty years ?

( 2 ) WHETHER, on the facts and in the circumstances of the case, the Tribunal was right in deleting the addition of Rs. 55,280 made by the Appellate Assistant Commissioner on account of excess depreciation in respect of the vessel 'tortugus' ?

( 3 ) WHETHER, on the facts and in the circumstances of the case, the Tribunal was justified in law in deleting the enhancement of Rs. 97,547 to the total income made by the Appellate Assistant Commissioner on account of wrong deduction of unabsorbed depreciation allowed by the Income-tax Officer ?"2. The assessee is a Norwegian shipping company. The assessment year involved is 1958-59. The previous year ended on December 31, 1957. The facts stated by the Tribunal may be briefly stated as follows: (i) Instead of furnishing the