Judgment :- JAYASIMHA BABU, J. The question referred to at the instance of the Revenue in respect of the assessee's assessment for the asst. yr. 1976-77 is as to whether on the facts and in the circumstances, the Tribunal was correct in holding that the assessee-company was entitled to the relief under s. 80HH in respect of its business which also comprised of business activities other than manufacturing ones ? 2. The Tribunal has held that the assessee had established its manufacturing business after 31st December, 1970, and that the assessee had to maintain necessary P&L a/c from which relief to be computed under s. 80HH was ascertainable. The Tribunal after observing that the only reason as to why the ITO did not grant relief to the assessee was that the ascertaining of income from the manufacturing and other activities was not possible, the assessee being also engaged in construction activity and the profit and loss being the one for both activities. The Tribunal took the view that the relief under s. 80HH is not for manufacturing activity but on the products made by the industrial undertaking, and division of activities like manufacturing and other activities is uncalled for. 3. That view of the Tribunal has been called into question by the Revenue. 4. Sec. 80HH(1) which is relied on reads as under : "Deduction in respect of profits and gains from newly established industrial undertakings or hotel business in backward areas : (1) Where the gross total income of an assessee includes any profits and gains derived from an industrial undertaking or the business of a hotel, to which this section applies, there shall, in accordance with and subject to the provisions of this section, be allowed, in computing the total income of the assessee, a deduction from such profits and gains of an amount equal to twenty per cent thereof". 5. The essential requirement to be satisfied by the assessee before he can obtain relief under this section is, in addition to fulfilling the criteria laid down under sub-s. (2) of s. 80HH is that its gross total income for the year includes the profits and gains derived from an industrial undertaking or the business of a hotel. 6. The term 'industrial undertaking' is not defined in the section. 6. The term 'industrial undertaking' is not defined in the section. However, sub-s. (2) throws light on the kind of activities that the industrial undertaking should be engaged in before it can be regarded as 'industrial undertaking' for the purpose of this section. 7. Sec. 80HH(2)(i) mandates that the assessee who claims benefit of this section should have begun 'manufacture' or 'production' of articles after 31st December, 1970, in any backward area. Though the term 'industrial undertaking' is capable of wider definition, and the word 'industry' has a very large ambit, the term 'industrial undertaking' used in s. 80HH(1), having regard to the requirements set out in s. 80HH(2)(i) is limited to industries which manufacture or produce articles. The assessee herein is engaged in addition to manufacture of article, also in construction activity and the profit account of the assessee includes profit and loss from the construction activity. That construction activity cannot be regarded as industrial undertaking; nor can it be taken into account on the ground that the same assessee is also carrying on manufacturing activity along with the construction activity. If the P&L a/c is capable of being separated and that part pertaining to the manufacturing activity ascertained, then to that extent, the assessee is entitled to claim benefit under s. 80HH. On the ground that the account is one and the activities of the assessee include manufacture cannot claim benefit under s. 80HH in respect of an activity which does not involve manufacture or production of articles. 8. We, therefore, answer the reference in the negative in favour of the Revenue and against the assessee. The Revenue is entitled to its costs.