Production of an article includes converting paddy into rice, supporting relief under the Income-tax Act provisions.

Converting paddy into rice constitutes production of an article for relief under Sections 32A, 80J and 80HH of the Income-tax Act, 1961, because the provisions extend beyond manufacture to production and the process yields a distinct article. The rejection based only on absence of manufacture was therefore incorrect, and the claimed relief was allowed in favour of the assessee.

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Issues: Whether converting paddy into rice amounts to production of an article for the purposes of relief under Sections 32A, 80J and 80HH of the Income-tax Act, 1961.

Analysis: The authorities below rejected the claim only on the ground that the activity did not amount to manufacture. The relevant provisions, however, extend relief not merely to manufacture but also to production. Applying the tests recognised in the cited authorities, the process of converting paddy into rice results in production of an article and satisfies the statutory requirement.

Conclusion: The issue is answered in favour of the assessee. The assessee is entitled to the claimed relief under Sections 32A, 80J and 80HH.

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