Sanjiv Khanna, J.

1. These two appeals by the Revenue relating to assessment years 2007-08 and 2008-09 require adjudication on the following substantial question of law:

“Whether the respondent assessee is entitled to benefit under Section 10B of the Income Tax Act, 1961 as he was engaged in manufacture or production of an article or thing?

2. These appeals arise from a common order of the Income Tax Appellate Tribunal (Tribunal, for short) dated 18th April, 2013.

3. The respondent assessee is a company engaged in the business of manufacture, trading and export of engineering goods etc. and also has a factory located in Noida Export Processing Zone, Uttar Pradesh. The said unit is a 100% export oriented and located in customs bounded area.

4. For the assessment year 2007-08, the respondent assessee had filed return declaring loss of Rs.4,11,190/- and had claimed deduction/exemption under Section 10B of the Income Tax Act, 1961 (Act, for short) on profit of Rs.69,69,429/- from the Noida Unit. The Assessing Officer did not allow deduction under Section 10B on the ground that the asse