Honble SINGH, J. — This is a reference application under Section 27(1) of the Wealth Tax Act,1957 at the instance of the Commissioner of Wealth-Taxjaipur to decide the following question of law namely: — "Whether on the facts and in the circumstances of the case, the Tribunal was justified in holding that the firm M/s.Vineet Trading Corporation is an Industrial undertaking and the assessee being one of its partners i.e. entitled to exemption under Section 5(1) (xxxii) of the Wealth Tax Act,1957 in regard to her capital investment in the said firm." (2). The assessee is an individual. She is a partner in the firm M/s.M.D.Jewellers, Jaipur. The assessee claimed exemption under Section 5(1) (xxxii) of the Wealth Tax Act, 1957 on the plea that M/s.M.D.Jewellers,is an Industrial Under-taking. The Wealth Tax Officer rejected the contention of the assessee. According to the Wealth Tax Officer the character of the stone is not changed and there was no manufacturing or processing of the stones in the business carried on by the assessee. The assessee appealed to the Appellate Assistant Commissioner. In an appeal it was contended that the law does not require that the "Industrial Under-taking" should be of a national importance or should be registered as an Industrial Under-taking. It was also contended that the partnership firm M/s. M.D. Jewellers, Jaipur used to purchase rough emeralds known as "Kharad" from the local market. After sorting out the rough emeralds, according to the size, they given to the Karigars who cut, shape and polish them in their own workshops or factories. The Karigars were paid labour charges, according to the work done. Thus, it was wrong to say that in the business carried on by the assessee no manufacturing or processing was involved. It was also pleaded that simply because the assessee was not having any plant or machinery or workshop for carrying on the work of manufacturing,the claim of exemption under Section 5(l)(xxxii) cannot be disallowed. However, the plea putforth by the assessee before the AAC failed and feeling dis-satisfied assessee preferred an appeal before the Tribunal. The Tribunal vide order dated July 11,1980 allowed the appeal of the assessee and reversed the finding of the AAC. However, the plea putforth by the assessee before the AAC failed and feeling dis-satisfied assessee preferred an appeal before the Tribunal. The Tribunal vide order dated July 11,1980 allowed the appeal of the assessee and reversed the finding of the AAC. On an application being moved by the Revenue before the Tribunal the Tribunal referred the present question for answer by this court we have heard Mr.G.S.Bapna, learned counsel appearing for the Revenue and Mr.N.M.Ranka, learned counsel for the assessee. Mr.Bapna contended that the Tribunal committed an error in granting the benefit of Section 5(l)(xxxii) to the assessee in the absence of specific finding that the manufacturing or processing of goods is done either wholly or even in some part by the firm of which the assessee is a partner. In support of his contention he placed reliance on a Division Benchs judgment of this court: Commissioner of Wealth-tax Vs. Vimal Chahd Daga (HUF) in (ITR), (1). Before we proceed to determine as to whether the Tribunal had recorded the requisite finding to bring the case within the ambit of Section 5(1) (xxxii) or not, we think, it proper to refer the findings of the Tribunal while reversing the finding of the AAC as under: — "We have heard the parties and perused the records. The facts of the case are not disputed. The assessee is one of the partners in the firm M/s. M.D.Jewellers,Jaipur. The business of the firm is to purchase rough emeralds from the local market and to manufacture rough emeralds into lawda potta etc. of out emeralds. In this process rough emeralds are first sorted out. Subsequently,they are cut later on they are converted into Ghats and finally shapped and then polished and coloured. Thus,the manufacturing is not done through the skilled labourers who were paid in accordance with the work done ty them. As a matter of fact,the aforesaid facts would go to show that the said firm is definitely an Industrial Undertaking. The method of manifacturing emeralds involve the process. We may also point out that for claiming Industrial Under-taking,it is not necessary that the assessee or the firm should own plot a machinery for doing such processing or manufacturing. In support of this proposition,we are fortified by the case of Mubarakali Khan(supra). The method of manifacturing emeralds involve the process. We may also point out that for claiming Industrial Under-taking,it is not necessary that the assessee or the firm should own plot a machinery for doing such processing or manufacturing. In support of this proposition,we are fortified by the case of Mubarakali Khan(supra). Even the finding of the Tribunal dated 31-7-1979 given in the case of WTA No.92/JP/78-79(supra) goes to show the same thing." (3). We have carefully perused the facts of the case of Commissioner of Wealth Tax Vs. Vimal Chand Daga(HUF) (supra) which are almost identical to the facts of the case and controversy involved was also almost the same. The facts of the case of Commissioner of Wealth Tax Vs.Vimal Chand Daga(supra) briefly stated are that the assessee was a partner in two firms which carry on the business of purchasing rough emerald from local market and then convert it into tawadda, potta and cut emerald by processing. It was stated that in this process,rough emeralds are sorted out,converted into ghats and finally shaped,polished and coloured and that manufacturing is got done through skilled labourers who are paid on the basis of work done. The assessee claimed that the firms of which he was a partner manufacture and process emerald and this activity make them "industrial undertakings"entitled to the Tribunal and on that basis the Tribunal granted the benefit of section 5(1) (xxxii) read with Explanation to Section 5(1) (xxxii) of the Act. The aforesaid facts were found proved by the benefit of section 5(l)(xxxii) of the Act read with Explanation. The finding of the Tribunal was reversed by this court in the case of Commissioner of Wealth Tax Vs. Vimal Chand Daga(supra) on the ground that no finding of fact was recorded by the Tribunal for holding that the firm was an "Industrial Undertaking" and the matter was remanded back to the Tribunal to decide the matter afresh. This Court after examining the matter recorded the finding: "We find that the Tribunal has not recorded the requisite findings of fact on the basis of which alone the benefit of the above,statutory provision can be given to the assessee. This Court after examining the matter recorded the finding: "We find that the Tribunal has not recorded the requisite findings of fact on the basis of which alone the benefit of the above,statutory provision can be given to the assessee. It was necessary for the Tribunal to record a clear finding about the entire activity or the various steps or stages in the manufacture or processing of these gems beginning with the point where the same was purchased in the local market and ending with the point where it was made marketable and sold by the assessees firms. It has then to be further found as to which.if any,of the various steps or stages of this manufacture of processing activity between these two end points is performed by the assessees firms directly so as to be treated as being done by the assessees firms themselves and also whether the activity got done through the skilled labourers who are paid on the basis of work done is an activity of the firms themselves and not of an outside agency. For this purpose, the jural relationship between the assessees firms and these skilled labourers has to be determined and it has to be decided whether the employer-employee relationship exists between them as claimed before us and on behalf of the assessee. We may add that the meaning of an "Industrial" defined in Section 2(j) of the Industrial Disputes Act as indicated in Banglore Water Supply and Sewerage Board Vs. Rajappa (2), may also be borne in mind in this context. The triple tests in that enterprise would also be helpful for this purpose. The matter has not been decided by the Tribunal or any of the authorities below it in this perspective for the obvious reason that the case was not put up by the parties in the correct perspective. Reference was made before us to a book "Indian Gemmology" by Raj Roof Tank which is stated to be an authoritative book on the subject in order to show the various stages of the manufacturing or processing activity of the gems beginning with the raw material known as "Kharad" and ending up with the gems in the marketing form. A perusal of the same indicates that there are several stages in between these two end points which together constitute the manufacture or processing of these goods. A perusal of the same indicates that there are several stages in between these two end points which together constitute the manufacture or processing of these goods. There is no finding by the Tribunal as to which, if any, of these several steps in the manufacture or processing of the goods is carried on by the assessees firms directly and whether the work done through the skilled labourers is not the entire manufacturing or processing activity. Without these findings of fact, it is not possible to decide the question of applicability of the statutory provision,of which the assessee has claimed the benefit." (4). We have carefully gone through the Division Benchs judgment of this court: Commissioner of Wealth Tax Vs. Vimal Chand Daga (supra) and we find ourselves in full agreement with the view that in the absence of the findings as indicated by the Division Bench of this Court in the case of CIT Vs.Vimal Chand Daga (supra), the Tribunal committed an error in granting exemption to the assessee under Section 5(l)(xxxii) of the Act. (5). We, therefore, decline to answer the question and require the Tribunal to decide the matter afresh in the light of the dictum laid down by this Court in Commissioner of Wealth Tax Vs. Vimalchand Daga(supra). There would be no order as to costs.