Assessee was created by National Dairy Development Act. Assessee filed return and claimed deduction under section 36(1)(viii) on ground that it was a provider of long term finance for agricultural and industrial development.  Assessing Officer denied said claim on grounds that notification declaring assessee as a financial institution was issued on 23-2-2004 which fell in subsequent assessment year.  Assessee contended that advances provided to industry engaged in milk producing were to be construed as an industrial undertaking. Dismissing the appeal the Court held that amount of expenditure relatable to ‘agricultural development’ under section 36(1)(viii) would not include or extend by taking within its sweep dairy or animal husbandry activity and, thus, providing long term finance for industrial or agricultural development to various dairy co-operations could not be covered as long term finance extended for agricultural or industrial development.  (AY. 2003-04)