( 1 ) THE following question of law has been referred for our opinion : "whether, on the facts and circumstances of the case, the Tribunal was justified in holding that the assessee was entitled to investment allowance under Section 32a on the aircraft radio ?"

( 2 ) THE answer to this question revolves around the interpretation to be put to Section 32a of the Income-tax Act, 1961, particularly, the expression "manufacture or production of any article or thing" as occurring in Sub-section (2) of that section.

( 3 ) THE assessee is Air Survey Co. of India (P.) Ltd. , and the assessment year relevant for our purpose is 1983-84. The assessee derives its income from surveying, mapping, aerial photography and aero-magnetic photography done for the Surveyor-General of India and the Atomic Mineral Division of Government of India. The assessee claimed investment allowance under Section 32a of the Income-tax Act, 1961, in respect of the aircraft-radio purchased in the previous year relevant to assessment year 1982-83. The Inspecting Assistant Commissioner (Assessment) rejected the assessee's claim on the ground that the activity of the assessee could not be called as manufacture or product

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