(1.) AT the instance of the Revenue, the following question of law is referred for our opinion in respect of asst. year 1979 80 :
(2.) WE have heard Mrs. Mona Bhatt, learned standing counsel for the Revenue. Though served, nobody appears on behalf of the respondent assessee.
(3.) AT the hearing of the reference, Mrs. Bhatt for the Revenue has pointed out that in the instant case the partnership firm was getting the goods prepared by an outside agency and therefore, was not entitled to exemption under S. 5(1)(xxxii) of the Act. Learned counsel heavily relied on the decision of the Division Bench of this Court in the case of CWT vs. Mohinibai Kanaiyalal (1999) 157 CTR (Guj) 298 : (1999) 240 ITR 636 (Guj), wherein this Court has laid down the following principle.