Held that in the manufacture of pickles, there was a change in the characteristic of the raw materials from that of vegetables to a pickle, whose use was also different. Moreover, section 80-IC(2) talked of manufacture or production and Schedule XIV to the Income-tax Act, 1961, gave the list of articles or things or operations under item I recognising fruit and vegetable processing industry manufacturing or producing canned or bottled products. Obviously, the assessee was a vegetable processing industry and, in terms of the Schedule, was manufacturing or producing the bottled product of pickles. There was no reason to hold that the assessee was not engaged in manufacturing activities. The process of manufacturing pickles from raw vegetables, fruits, masala and other ingredients brought about a new and different marketable commodity than the raw material. Entitle to deduction.   Held that the assessee had produced bank realisation certificates, bank certified statement of forex receipts and certificate of the auditor to show the realisation of export proceeds. There was no infirmity in the order of the Commissioner (Appeals) in allowing the assessee’s claim under section 10B to the extent of foreign exchange received during the specified period. Both of the assessee’s units had became 100 per cent. export-oriented units. The Commissioner (Appeals) gave a categorical finding about acquisition of the machinery in different years after obtaining the remand report. There was no reason to sustain the disallowance made by the Assessing Officer.  (AY.2001-02 to 2008-09)