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 Secondly, in so far as rate of depreciation on computer software is concerned, now it is well settled proposition of various courts including that of Hon'ble Jurisdictional High Court that deprecation for the computer peripherals and the software has to be allowed @60% and hence on this count also depreciation allowed @60% by the ld. CIT (A) is correct in law.

 Lastly, on the issue of additional allowance of depreciation, it has been elaborately discussed that the assessee has been treated as manufacturer under Excise Duty Act whereby it is converting compressed natural gas from natural gas which has been reckoned as manufacturing process. Once all these facts have been duly appreciated during the course of original assessment proceedings and same has been allowed by the Assessing Officer, then there was no reason to take a different opinion without any tangible material coming on record, either suggesting that assessee is not a manufacturer at all for which it is not entitled for claim of additional allowance of depreciation.