ADARSH KUMAR GOEL, J. - (1.) THE Revenue has preferred this appeal under s. 260A of the IT Act, 1961 (in short, 'the Act') against the order of the 2001 -02, proposing to raise following substantial question of law : "Whether on the facts and in law, the Hon'ble Tribunal was justified in holding that deduction under s. 80 -IB is permissible on income derived from processing activities as processing activities do not constitute manufacture of a product -
(2.) THE assessee is engaged in manufacturing and trading of tractor and auto parts and also doing job work of similar nature. It claimed deduction under s. 80 -IB of the Act and income from job work, which was partly allowed by the AO. On appeal, the CIT(A) upheld the plea of the assessee, which has been affirmed by the Tribunal.
(3.) WE have heard learned counsel for the Revenue. Only contention raised on behalf of the Revenue is that the assessee may be entitled to deduction under s. 80 -IB of the Act in respect of income derived from its own manufacturing but the said deduction was not admissible for the job work done for others.;