The term “manufacture” was not defined in the substituted provisions as was available before its substitution to include even processing. Explanations to this section define certain terms used. Explanation 3 was added in the section which begins with the words “for the removal of doubts”. It is to treat the profits and gains derived from onsite development of computer software outside India as income deemed to be derived from export of computer. Explanation 4 was added by the Finance Act, 2003, with effect from April 1, 2004 to define “manufacture or produce” to include cutting and polishing of precious and semi precious stones. The insertion of Explanation 4 clearly establishes the fact that wherever the benefit was to be extended, the needful was done. It had been authoritatively held by the Supreme Court in CIT v. Tara Agencies (2007) 292 ITR 444 (SC)  that mixing of different kinds of tea does not fall within the ambit of manufacturing. Court held that   blending of tea does not amount to manufacture and the assessee was not entitled to the benefit of section 10B. Court also held that while interpreting the provision for exemption, in case of ambiguity in an exemption provision the benefit has to go to the revenue. Followed Commissioner Customs v. Dilip Kumar and Co. (2018) 6GSTR-OL-46  (SC). (AY.2002-03 to 2005-06)