- (1.) The question to be considered reads thus : Whether, on the facts and in the circumstances of the case, the assessee-firm is an industrial undertaking eligible for deduction u/s. 80HH, 80-I and 80J of the Income-tax Act, 1961
(2.) All that is on record in regard to the process that the assessee carries on is stated in the order of the AAC thus : But if an analysis of the activity of making powder from the chicory roots is made, it will be found out that there are only two processes in making the powder from chicory roots, (i) roots are roasted, and (ii) after that they are powdered.
(3.) We have asked the learned counsel for the assessee whether there is anything else that describes the process. There is apparently nothing else. If that is the only process, it does not satisfy the test laid down by this Court in Aspinwall & Co. Ltd. V/s. CIT, 2001 251 ITR 3231.;