“In our opinion, when the assessee purchased assets at a price, its liability to pay the same arose simultaneously. Merely because the said that the liability was to be discharged in instalments become due and payable. It was that liability which has increased on account of fluctuation in the rate of exchange. In our opinion, the contention raised on behalf of the revenue that the liability to pay the price of the asset arose only when the instalments became due and payable cannot be accepted for the reason that we are considering a provision which is made inter alia, for the purpose of determining the allowability of depreciation allowance. If the assessee become the owner of the machinery and starts using the same, it would become entitled to depreciation allowance. It is for the purpose of working out the amount of depreciation that one has to look at the cost of the asset in respect of which depreciation is claimed. It is in this context that we have to consider as to when the liability can be said to have arisen. If the contention raised on behalf of the Revenue is accepted, then it would defeat the very purpose of the provision. As view to mitigate hardships which were likely to be caused to the assessee as a result of fluctuation in the
