Tribunal held that rendering software development services is regarded as an industrial undertaking engaged in manufacture of article or thing. Accordingly the software professional who were employees of assessee-company could be considered as workman, hence eligible for deduction. Followed  ESI Corpn. v. Reliable Software Systems (P.) Ltd. [2012] 5 AIR Bom. R 795 (para  12] ACIT v. . Texas Instruments (India) (P.) Ltd. [2009] 27 SOT 72 (URO) (Bang.)(Trib.). The Tribunal held that Software Industry has also been notified as Industry for the purpose of Industrial Disputes Act, 1947 by the State of Karnataka and that the employees employed in software development industry render technical services and not services in the nature of supervisory or management character. (AY.2012-13)