Allowing the appeal of the assessee , the Court held that ; assessee which is engaged in manufacture of Aurvedic medical products , filling of mushroom powder in gelatin capsules after following specified process amounts to manufacture or production of commercially distinct commodity . Accordingly entitle to deduction . (AY. 2003-04 ,2004-05)
(Note: Order in DXN Herbal Manufacturing (India) (P.) Ltd. v. ITO ( 2009) 316 ITR (AT) 126 ( Chennai)( Trib) is partly reversed .)