What is the meaning of manufacture for the purpose of Income Tax (section 35B)?

Does it include processing activity?

Whether the activity of blending of tea of diverse grade or brands by mixing different kinds of tea amounts to manufacture for the purpose of weighted deduction u/s 35B(1A)?

Whether the provisions of Section 2(f) of Central Excise Act, 1944 (definition of manufacture) be applied in Income Tax also?

All these questions have been discussed at length by the honorable Supreme Court in a recent matter (reported in 2007 -TMI - 1591 - SUPREME COURT OF INDIA)

After considering various issues, honorable Supreme Court has held that

On clear construction and interpretation of Section 35B(1A) of the Act, we are clearly of the opinion that the respondent's activity amounts to "processing" only and the activity does not amount to either "production" or  "manufacture". The term "processing" has not been included in Section 35B(1A) of the Act, therefore, the respondent is not entitled for weighted deduction under Section 35B(1A) of the Act.

Manufacture scope excludes processing; blending tea is processing and not eligible for weighted tax deduction. The court concluded that blending of tea amounts to processing only and does not constitute production or manufacture for the weighted deduction provision; since processing is not included in the statutory wording, such activity does not qualify for the weighted deduction.