The assessee manufactured, processed and exported sea foods and was a 100 per cent. export oriented unit.  The assessee claimed deduction u/s10B of the Act on the ground that the marine product dealt by it was specifically known as pasteurized crab meat which was distinct from raw meat as manufacturing activities were undertaken with various machinery and with skilled labour, that its operation was recognized as a manufacturing activity and granted the status of 100 per cent. export oriented unit and therefore, definition of the word “manufacture” as contained in section 2(r) of the Special Economic Zone Act, 2005 applied and that conversion of live crab into edible canned product was entitled for deduction under section 10B . Further, it was submitted that the definition of the term “manufacture” was inserted in the 1961 Act with effect from April 1, 2009 and it was only for undertakings which commenced business after April 1, 2009, i. e., with effect from April 1, 2010, that the statute distinguished that the processing, preservation and packaging of marine products would not amount to manufacture or production of article or thing with insertion of section 80IB(11A) .The claim was not allowed by the AO and which was affirmed by the CIT (A) and Tribunal . on appeal the Court held that the Assessing Officer, the Commissioner (Appeals) and the Tribunal had abdicated their responsibility as fact finding authorities in not examining the nature of activity of the assessee before referring to the various decisions, which according to the Tribunal resulted in the assessee’s appeal being dismissed. The first and foremost job entrusted to an Officer was to examine the nature of activity done by the assessee, which was claimed to be a manufacturing process. The authorities invariably visit the facility established by the assessee to gain first hand knowledge about the claim made by the assessee. Had the Assessing officer taken such step the finding might have been wholly different or slightly different or it could have been a well reasoned order. The Tribunal as the last fact finding authority, was bound to examine the full facts. The contentions had been extracted verbatim in its order to hold that there was no change in the substance used in live crab or used it as by extracting it as meat from the same live crab by the assessee and that the input and output were the same, which was crab. There was no dispute to the fact that what was canned was crab meat.The matter required to be re-examined in a proper perspective. The orders passed by the Tribunal, Commissioner (Appeals) and the assessment orders were set aside and the matter was remanded to the Assessing Officer. (AY. 2005-06, 2006-07, 2008-09 to 2011-12)