(1.) Heard the learned counsel for both sides.
(2.) The Revenue has filed the present Appeal aggrieved by the order passed by the Income Tax Appellate Tribunal on 7.12.2012 holding in favour of the Assessee that the process of converting raw Urad into Urad Dhal was a manufacturing activity and therefore, the Assessee is entitled to deduction under Section 80IA of the Act.
(3.) The Appeal was admitted by a co-ordinate Bench of this court by its order dated 22.8.2013, raising the following purported substantial question of law:-