Assessee engaged in growing/cultivation of tea as well as manufacturing of tea in Assam.  Assessee claimed deduction u/s. 80IC(2)(b) in respect of sale of black tea manufactured from green leaf purchased. The AO found that assessee did not cultivate / plant green tea itself for manufacturing black tea, and therefore rejected claim. Tribunal held that until and unless assessee engages with both conditions of processing and raising of planation of tea, it cannot be allowed deduction u/s. 80IC(2)(b).  Accordingly the  assessee  is  not eligible to claim deduction u/s. 80IC(2)(b) in respect of green tea leaf purchased from outside market.  (AY.2011– 2012)