https://www.taxtmi.com/caselaws?id=78306 Blending and packing of tea in a Special Economic Zone unit was treated as manufacture or production for Section 10A purposes because the export incentive provision must be construed reasonably and in favour of the assessee. The court noted that the export policy definition of manufacture was wide enough to cover processing activities such as repacking, and that blending gave tea a distinct flavour and character. The later SEZ Act definition incorporated in Section 10AA was viewed as clarificatory and consistent with the same legislative policy, supporting the same understanding under Section 10A. Deduction was therefore available for the assessment year 2004-2005. en-us Mon, 17 Aug 2009 00:00:00 +0530 Wed, 12 Nov 2025 17:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78306 Blending and packing of tea in a Special Economic Zone unit was treated as manufacture or production for Section 10A purposes because the export incentive provision must be construed reasonably and in favour of the assessee. The court noted that the export policy definition of manufacture was wide enough to cover processing activities such as repacking, and that blending gave tea a distinct flavour and character. The later SEZ Act definition incorporated in Section 10AA was viewed as clarificatory and consistent with the same legislative policy, supporting the same understanding under Section 10A. Deduction was therefore available for the assessment year 2004-2005. Case-Laws Income Tax Mon, 17 Aug 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78306