Subsequently, on March 9, 1953, in exercise of the powers conferred upon it by Section 60A of the Indian Income tax Act, 1922, an Explanation was added by the Central Government to the above Clause (2) of the Order of 1950 with effect from that date and that Explanation was in the following terms: "For the purpose of this paragraph, the ex pression 'all depreciation actually allowed under any laws or rules of a Part B State ' means and shall be deemed always to have meant the aggregate allowance for depreciation taken into account in computing the written down value under any laws or rules of a Part B State or carried forward under the said laws or rules." In Commissioner of Income tax, Hyderabad vs D.B.R. Mills Ltd., the Hyderabad High Court held that this Explanation was ultra vires the powers of the Central Government under Section 60A of the Indian Income tax Act, 1922.