1. - In this special appeal, a short but interesting question that arises for consideration is whether the blending of different types of tea by the assessee amounts to production of a thing or an article by an industrial undertaking within the meaning of the expression as used in section 80-IB of the Income-tax Act, 1961, though it may not amount to manufacture of goods in the sense of bringing into existence altogether a new and different thing as known differently in the commercial parlance in the market where tea is transacted.

2. The appellant-assessee has set up a small-scale industrial unit in the backward industrial area of Banswara. The appellant’s case is that it purchased tea leaves powder/granules and these tea leaves are collected by marking the name of the garden and lot number. The samples of available quality are dispatched to the “blend master” who after going through his own process, suggests the mixing ratio and process of mixing for making the perfect blend of tea. The activity of blending of different types of leaves obtained from different gardens in a definite ratio results in production of a commodity having its own identity and though may not amount