Dismissing the appeal of the revenue the Court held that the entire factual matrix had not only been analysed by the Commissioner (Appeals), but, also by the Tribunal. The Tribunal was 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 S. 10AA . ( AY.2013-14)