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1. The applicants are shipowners. Between August 1956 and September 1959 they operated one vessel, but at the end of that period they sold her at a sub tantial loss and I think it is not disputed that after allowing for depreciation at the rate prescribed by the Inland Revenue Ordinance they would have been entitled to a balancing allowance under s. 38 in the sum of $1,050,190 against subsequent profits. From September 1959 until 1963, however, the company neither owned nor operated any vessel a