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1991 (4) TMI 93 - HC - Income TaxExtract: ....... of Bombay 1959 10 STC 500, we are inclined to agree with the Tribunal that mere blending of tea for the purpose of export does not constitute manufacture of articles within the meaning of section 2(5)(a)(ii). Accordingly, we would answer the question referred to us by the Tribunal in the negative and in favour of the Revenue. No order as to costs.
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