The assessee claimed deduction under section 80-IA of the Income-tax Act, 1961 on its production of gitti from sand stone blocks. The Assessing Officer rejected the claim on the ground that such activity could not be categorized as “manufacturing” or “production”. The Commissioner (Appeals) allowed the assessee’s appeal. On appeal by the Department, the Tribunal reversed his order. On the appeal the Court held that   the expression production used under section 80-IB, in which expressions manufacture and production both were used were synonyms with each other or the word production had a wider meaning than manufacture so as to include within the preview, an activity, which might not amount to manufacture but might still amount to production. Appeal of the assessee is allowed. Order of Tribunal is set aside.  (AY. 2003-04)