AJAY KUMAR MITTAL, J. - (1.) THIS order shall dispose of ITA Nos. 302, 303, 304, 316 and 361 of 2008, as according to learned counsel for the parties, common questions of law and facts are involved therein. For brevity, the facts are being taken from ITA No. 302 of 2008.
(2.) THIS appeal has been filed by the revenue under Section 260A of the Income Tax Act, 1961 (in short "the Act") against the order dated 10.8.2007 passed by the Income Tax Appellate Tribunal, Chandigarh Bench "A", Chandigarh (hereinafter referred to as "the Tribunal") in ITA No. 368/Chandi/03, relating to the assessment year 2000-01. The appeal was admitted by this Court vide order dated 18.9.2008 for determination of the following substantial question of law:- "Whether in the facts and circumstances of the case the ITAT was right in holding that the activity of the assessee of manufacturing of identity cards amounts to 'manufacture' and the undertaking of the assessee is an 'industrial undertaking' for the purpose of Section 80-IA of the Act, and the assessee is eligible for benefit u/s 80-IA of the Act?"
(3.) BRIEFLY stated, the facts necessary for adjudication as narrated in the appeal are that the assessee filed its return for the assessment year 2000-01 on 29.11.2000 declaring an income of Rs.1,30,31,964/- which was processed on 25.1.2001. It claimed deduction of Rs.21,68,157/- under Section 80-IA of the Act. Proceedings under Section 148 of the Act were initiated. The Assessing Officer disallowed the claim of the assessee vide order dated 5.12.2002. Feeling aggrieved, the assessee took the matter in appeal before the Commissioner of Income Tax (Appeals) [in short "the CIT (A)"] who vide order dated 7.3.2003 upheld the order of the Assessing Officer and dismissed the appeal. Being dissatisfied, the assessee approached the Tribunal by way of an appeal. The Tribunal vide order dated 10.8.2007 allowed the appeal holding that the assessee was eligible for benefit under Section 80-IA of the Act. The revenue has challenged the said order in the present appeal.;