DIPAK KUMAR SEN, J.

( 1 ) S. B. COLD Storage Industries Pvt. Ltd. , the assessee, owns and runs a cold storage plant for storage of potatoes. The assessee was assessed to income-tax for the assessment year 1979-80, the accounting year ending on December 31, 1978. In the assessment, the assessee claimed investment allowance under Section 32a of the Income-tax Act, 1961, contending that it had installed new plant and machinery of the value of Rs. 2,29,315 in the cold storage during the accounting year which had been used wholly and exclusively for the purpose of its business. The investment allowance was claimed on the said amount. The assessee contended that an amount of over 75% of its claim for investment allowance had been debited in its profit and loss account of the year involved under an " Investment Allowance Reserve Account". The assessee contended that the operations in its cold storage plant amounted to manufacture, the main operation being processing of potatoes by chilling so that they remained fresh.

( 2 ) THE Income-tax Officer rejected the contention of the assessee holding that the plant and machinery installed by the assessee were not used for the purpose of any b

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