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7. The assessing officer disallowed the claim of higher depreciation at 60%, on the following remarks, "The depreciation in respect above machineries was claimed at the rate of 60% under the head computers. Only computers including computer software is eligible for depreciation at 60% as classified in SI. No.5 under the heading III. Plant and Machinery of Part- A of the depreciation table. The above machineries are computerized machines and are not computers classified in the depreciation table. Hence they are eligible for depreciation @ 15% only. Accordingly the excess depreciation of Rs. 17,13,508/- and Rs.9,01,181 calculated above is disallowed and added to the total income."

14. Though, reiterating the very same submissions made before the appellate authority, Mr.S.Sridhar, learned counsel for the appellant-assessee, assailed the correctness of the order, stated supra, made submissions on the substantial questions of law and prayed for an answer, in favour of the assessee, going through the material on record and the orders of the authorities and tribunal, we do not find any manifest error. On the other hand, we are of the considered opinion that orders of the authorities and the appellate tribunal, are correct, in holding that the machineries, for which, depreciation to the extent, sought for, do not fall under the definition, "computer, including computer software". Fact that the machineries do not fall under the abovesaid category, cannot be termed as perverse and therefore, the order impugned, does not call for interference.