Assessee which is in business of converting herbs into a certain herbal product by manual process. It used some chemicals and small machinery and most processes of its manufacturing did not require electricity. AO denied the exemption. Tribunal held that purchase of plant and machinery and consumption of electricity are not mandatory requirements to claim deduction and manufacturing of herbal product by assessee would amount to manufacture of a different commercial article. Order of Tribunal is affirmed by High Court. (AY. 1996-97 to 1998-99)