1 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1172 OF 2009 The Commissioner of Income Tax ..Appellant. V/s. M/s. Killick Nixon Ltd. ..Respondent. Mr. Suresh Kumar for appellant. Mr. Sanjiv M. Shah for respondent. CORAM : V.C.DAGA AND J.P.DEVADHAR, JJ. DATED : 16TH SEPTEMBER, 2009. P.C. :- 1. Heard learned counsel for the revenue and learned counsel appearing for the respondent. The revenue has sought to raise as many as 6 questions of law. The questions (a), (e) and (f) are relates to depreciation claimed by the assessee on sugar mill roller. The said issue has been considered by the Tribunal at page Nos.74, 78, 98 and 101 of the impugned order. The Tribunal has appreciated the evidence and recorded findings of fact. We see no fault with the findings recorded by the Tribunal. 2. So far question (b), (c) & (d) are concerned, they relate to the manning services and agency services rendered by the assessee based on the agreement entered into with the foreign shipping companies. This document together with the nature of services provided are also discussed by the Tribunal on page Nos.98 and 101, wherein the Tribunal has, after 2 appreciating the evidence, recorded the findings of the fact in the following words:- “....Marine operations are highly technical and complex operations, therefore, provision of crew with direct and in-direct responsibilities for safe operations of the ship owned by the principals is a technical service, hence, the assessee is entitled for deduction on the income earned in foreign currency u/s.80-O of the Act.....” 3. Having seen the findings recorded by the Tribunal on all the three questions, which revolve around the appreciation of evidence, we do not see any substantial question of law arise in the appeal. The appeal is, therefore, dismissed in limini with no order as to costs. (J.P.DEVADHAR, J.) (V.C.DAGA, J.)