Manufacture through cloth processing supports investment allowance where bleaching, dyeing and printing are treated as production activity.

Bleaching, dyeing, printing and allied processing of cloth were treated as manufacture or production for investment allowance purposes under the Income-tax Act, 1961, because prior binding authority had already recognised these processes as manufacturing activity. The cited Full Bench view on dyeing, bleaching, printing and embroidering of grey cloth reinforced that such processing amounts to production and manufacture, supporting eligibility for investment allowance under section 32A. On that basis, the proposed issue was not open for reconsideration and no substantial question of law arose for the revenue's appeal.

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Issues: Whether bleaching, dyeing, printing and allied processing of cloth amounted to manufacture or production so as to entitle the assessee to investment allowance under section 32A of the Income-tax Act, 1961, and whether any substantial question of law arose for consideration in the revenue's appeal.

Analysis: Prior binding authority had already held that bleaching, dyeing and printing constitute manufacture within the meaning of the relevant fiscal provisions. A Full Bench of the same High Court had further held that dyeing, bleaching, printing and embroidering of grey cloth amount to production and manufacture under the Income-tax Act, 1961, thereby supporting eligibility for investment allowance. In light of these precedents, the issue was no longer open for reconsideration and the proposed question did not disclose a substantial question of law.

Conclusion: The process in question was held to amount to manufacture or production, the assessee was entitled to investment allowance, and the revenue's appeal was not maintainable on the ground of any substantial question of law.

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