JUDGMENT

B. P. JEEVAN REDDY, J.:—Two groups of appeals are placed before us for hearing. The first group involves the interpretation of identical words occurring in Section 80-HH and Section 84 viz., "manufacture or produce articles" whereas the second group is concerned with the words "construction, manufacture or production of any article or thing" in Section 32-A of the Income-tax Act. Civil Appeals 4238-4240 of 1983 can be said to be representative of the first group whereas the second group of appeals comprise Civil Appeals 4239 to 4248 of 1992.

2. The first group of appeals is directed against the Judgment of a Division Bench of Orissa High Court answering the question referred to it under Section 256(2) in favour of the assessee. The question referred is to the following effect: "Whether on the facts found by the Appellate Tribunal, the assessee is entitled to the benefit provided under Section 80-HH of the Income-tax Act, 1961?" The assessment years concerned are 1974-75 and 1975-76. The respondent-assessee is a firm of contractors constituted for the purpose of construction of a dam in Orissa. It was constituted under a partnership deed dated January 14, 1972. It was given