The Tribunal held that  a process of “manufacture” as defined under the 2005 Act had taken place in the assessee’s special economic zone unit and that the Assessing Officer himself had accepted that the assessee’s unit, processed the raw materials by removing 10 to 20 per cent. impurities, that the cost comparison of the semi-finished product with that of the raw material was also referred to and that the Department had not proved that the certificate issued by the Assistant Development Officer of the Special Economic Zones was not genuine.  Accordingly the activity of    sieving to separate dust particles. is held to be manufacturing activity. On appeal by  the revenue the Court held that  the Tribunal is  right in holding that the assessee carried on manufacturing activity even though a new product having a distinctive name, character or use was not brought into existence at its special economic zone unit by it and that the assessee was eligible for deduction under section 10AA. (AY.2013-14)