Tribunal held that  what was the process done by the assessee and whether or not there was actual manufacture had not been shown on record. The licence issued to the assessee as a 100 per cent. export oriented undertaking showed that under the head “products manufactured” it was specified “processed foods, pickles, fresh fruits and vegetables”. Admittedly, fresh fruits and vegetables were not manufactured items. What was the break-up of the processed foods, pickles, fresh fruits and vegetables which have been exported, had not been brought on record. In the assessment order, the Assessing Officer had made a blanket disallowance, the assessee had only given a general reply and claimed the issue to be covered by various case law. Neither the Department nor the assessee had placed the facts before the Tribunal. Therefore the issue was restored to the Assessing Officer for readjudication after verification, if necessary physical verification, as to the activities undertaken by the assessee at its eligible unit in respect of which claim of deduction under section 10B was being made. As to whether there was manufacture per se, or not, what was the break-up of the exports of the processed foods, pickles, fresh vegetables and fruits separately, and after determining all the facts, the Assessing Officer shall readjudicate the issue after granting the assessee adequate opportunity to substantiate its case. ( AY.2006-07)