Judgment N.K.Sud, J. 1. In these cross references filed by the assessee as well as the Revenue, the Income-tax Appellate Tribunal, Chandigarh Bench, Chandigarh (for short, "the Tribunal"), has referred the following questions of law arising out of its order dated April 21, 1988, relating to the assessment year 1981-82, for the opinion of this court : At the instance of the assessee : "1. Whether, on the facts and circumstances of the case, the Income-tax Appellate Tribunal was right in law in not having allowed initial depredation on an amount of Rs. 13,502 being the expenditure on water cooler places, in view of Section 32(1) (iv) ? 2. Whether the Income-tax Appellate Tribunal was right in law in having treated the amount of Rs. 1,56,393 earned by it from sale of import entitlements as constituting revenue receipt, liable to tax ? 3. Whether the Income-tax Appellate Tribunal has correctly interpreted Rule 6D(2) while disallowing a sum of Rs. 2,000 out of the travelling expenses ?" At the instance of Revenue (marked as question No. 1-A by us) : "(1-A) Whether, on the facts and in the circumstances of the case, the Appellate Tribunal is right in law in allowing initial depreciation on the construction of cycle stand for workers (cable unit) as well as for that of (XLPE unit) which items have not been specifically mentioned in Section 32(1) (iv) of the Income-tax Act, 1961 ?" Questions Nos. 1 and 1A : 2 The facts relevant to this issue are that the assessee claimed initial depreciation under Section 32(1) (iv) of the Income-tax Act, 1961 (for short, "the Act"), on the following assets : 314-mk..kk.htm 3. The Assessing Officer did not allow the claim of the assessee, as according to him, neither the cycle stands nor water cooler places were covered in any of the items referred in Section 32(1) (iv) of the Act. The Commissioner of Income-tax (Appeals) confirmed the order of the Assessing Officer. On further appeal by the assessee, the Tribunal, following its earlier order in the case of the assessee itself for the assessment year 1978-79, allowed the claim of the assessee in respect of the cycle stands. The Commissioner of Income-tax (Appeals) confirmed the order of the Assessing Officer. On further appeal by the assessee, the Tribunal, following its earlier order in the case of the assessee itself for the assessment year 1978-79, allowed the claim of the assessee in respect of the cycle stands. However, the Tribunal held that the assessee was not eligible to claim initial depreciation on water cooler places as the same did not fall in any of the categories of the buildings specified in Section 32(1) (iv) of the Act. 4. Under Section 32(1)(iv) initial depreciation is admissible on "canteens, hospitals, shelters, etc". While dealing with the claim of the assessee on initial depreciation in the assessment year 1978-79, the Tribunal held that the cycle sheds were covered under the categories of the buildings specified in the above provision. 5. On a specific query from counsel for the Revenue, he has not been able to show that the finding of the Tribunal in the assessment year 1978-79 had been challenged by the Revenue. Even otherwise, we are satisfied that the interpretation placed by the Tribunal in the assessment year 1978-79 is correct. Since the relief has been granted to the assessee on the basis of finding recorded in the assessment year 1978-79, which has become final, we are satisfied that the Tribunal was right in allowing the claim of the assessee for initial depreciation on cycle sheds. 6. In so far as the claim for initial depreciation on water cooler places is concerned, counsel for the assessee has not been able to satisfy us as to how the same could be said to be covered in any of the categories of the buildings specified in Section 32(1) (iv) of the Act, viz., canteens, hospitals, shelters, etc. It is not even a building of a similar nature. Thus, in our view, the Tribunal was justified in rejecting the claim of the assessee in this behalf. 7. Accordingly, question No. 1 in the assessees reference is answered in the affirmative, i.e., against the assessee and in favour of the Revenue. Similarly question No. 1-A is also answered in the affirmative, i.e., against the Revenue and in favour of the assessee. Question No. 2 : 8. 7. Accordingly, question No. 1 in the assessees reference is answered in the affirmative, i.e., against the assessee and in favour of the Revenue. Similarly question No. 1-A is also answered in the affirmative, i.e., against the Revenue and in favour of the assessee. Question No. 2 : 8. Counsel for the assessee fairly concedes that in view of the incorporation of clause (iiia) in Section 28 of the Act with effect from April 1, 1962, profit on sale of import entitlements has been rightly included in the total taxable income of the assessee. Accordingly, this question is answered in the affirmative, i.e., against the assessee and in favour of the Revenue. Question No. 3 : 9. The assessee engaged certain professional retainers who were the employees of the assessee-company. While allowing their claims on account of travelling, etc., the Assessing Officer made a disallowance of Rs. 2,000 by invoking the provisions of Rule 6D(2) of the Income-tax Rules, 1962. According to the Assessing Officer, Rule 6D(2) was applicable to professional retainers also as in addition to the employees, the same was also applicable to "any other person". The assessee, on the other hand, contended that this Rule was not applicable to the professionals. The disallowance made by the Assessing Officer was upheld by the Commissioner of Income-tax (Appeals). The Tribunal on further appeal upheld the disallowance by observing as under : "We have heard both the parties at length. The nature of the services rendered by the professionals has not been discussed either by the Assessing Officer or the Commissioner of Income-tax (Appeals). Be that as it may, Rule 6D(2) refers to the words any other person. This has not been defined in the Act. It has, therefore, to be considered in its wider sense. The words any other person cannot be restricted to the directors of the company alone. These cover any other person who is travelling in connection with the business of the company. If a professional has travelled in connection with the business of the company, the provision of the Rule 6D(2) will clearly be attracted. The order of the Commissioner of Income-tax (Appeals) is, therefore, reversed on this account and that of the Assessing Officer restored." 10. We are in agreement with the interpretation placed by the Tribunal to the words "any other person". This expression is broad enough to include professionals within its ambit. The order of the Commissioner of Income-tax (Appeals) is, therefore, reversed on this account and that of the Assessing Officer restored." 10. We are in agreement with the interpretation placed by the Tribunal to the words "any other person". This expression is broad enough to include professionals within its ambit. Accordingly, this question is also answered in the affirmative, i.e., against the assessee and in favour of the Revenue.