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37. In the submissions made before ld. CIT(A), the assessee had submitted as under:
6.1 "In this regard, the ld. AR vide written submission dt. 26.05.2009 has argued as under:
"The assessee hascharged60% depreciation as they fall under item (5) of the depreciation schedule in the I.T. Rules, 1962 "Computer including computer software" under the major head "machinery and plant". Copy of the rules is enclosed. We are enclosing the photocopy of the relevant page of the tables. Secondly below the table at note No.7 it is also mentioned that 'computer software' means any computer program recorded on any disk, tape, perforated media or other information storage devise i.e., not only the hardware but the software is also entitled for depreciation @ 60%. Your goodself will appreciate that after the introduction of "block of assets" concept the computer head which is depreciated at the rate of 60% is one single block of assets. Therefore, the cost of the assets of LAN, WAN equipments gets merged into the other computer costs and, therefore, the current year additions is made available.