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2008 (12) TMI 746 - HC - Income TaxDeduction u/s 80-IA - business carried out by the assessee amounted to manufacturing of article or things for the purpose of deduction or not. HELD THAT:- It is well settled that every change or process cannot be termed as manufacture or production. Well known tests applied for determining whether a process amounted to manufacture or production are that a new and distinct commercial product is produced. In each case, it may be a question of fact whether a particular process involves manufacture or not. The question may be of degree and extent of change and though, the issue may at times be debatable, by applying the relevant tests, the Tribunal has recorded a finding and such finding cannot be held to be perverse, it cannot be held that a substantial question of law arises.The Tribunal has applied the correct test and recorded a finding that the process undertaken by the assessee involved manufacture. Merely because a different view can be taken will not be a ground to hold that a substantial question of law arises. In a recent order of this Court in CIT v. Mahesh Chadra Sharma [2008 (10) TMI 68 - PUNJAB AND HARYANA HIGH COURT], dealing with an identical issue. Thus, the question raised cannot be held to be a substantial question of law. Hence, dismissed.
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