Court held that the scope of deduction under section 80-IA of the Act was limited to determination of the quantum of deduction treating the eligible business as the only source of income. The deduction could not be denied because the deduction under section 80-IA had to be computed unit-wise and not for the business as a whole. The Tribunal was justified in allowing the deduction under section 80-IA even though the assessee had declared loss under the head profits and gains of business. Dismissing the appeal the Court held that the  raw seeds which could be the subject matter of human consumption, after undergoing the various process stages, ceased to be edible and could only be used for cultivation. Even applying the commercial test, the Tribunal, on the facts, had found that in the market, the final output was known to be used only for cultivation. The Tribunal was right in coming to the conclusion that a different commodity emerged after the raw seeds underwent the different stages of processing. The Assessing Officer was wrong in holding that the activity carried on by the assessee in its industrial undertakings did not amount to manufacture or production of articles or things. Followed CIT v. Jalna Seeds Processing and Refrigeration Co. Ltd (2000) 246 ITR 156 (Bom.)(HC). (AY. 1996-97)