Judgment :- R. JAYASIMHA BABU, J. The assessee is engaged in the processing of unbleached grey cloth by bleaching, calendering, dyeing and printing so as to produce printed cloth. For the asst. yr. 1981-82, the assessee claimed deduction under s. 32A which claim was rejected by the IAC who under s. 144B directed the ITO to disallow the claim. On appeal the CIT(A) granted that deduction. He did so following the decision of the Tribunal for the asst. yrs. 1979-80 and 1980-81. The Revenue have appealed to the Tribunal against the order of the CIT(A). The Tribunal affirmed the order of the CIT(A) relying on the decision of the Supreme Court in the case of Empire Industries Ltd. & Anr. vs. Union of India & Ors. 1987 (162) ITR 846 (SC) and the case of Ujagar Prints vs. Union of India & Ors. 1989 75 CTR (SC) (Allied Laws) 1. Before us, the learned senior counsel for the Revenue submitted that in the light of the recent decision of the Supreme Court in the case of S. S. M. Brothers (P) Ltd. vs. CIT decided on 12th January, 1999, there is no error in the order of the Tribunal and the question is to be answered in favour of the assessee. In the aforementioned case, it was held by the Supreme Court that when s. 33(1)(b)(B)(i) is read along with item 32 of the Fifth Schedule of the IT Act that item being, "32. Textiles (including those dyed, printed or otherwise processed) made wholly or mainly or cotton, including cotton yarn, hosiery and rope"read together, the result is. " Where the machinery or plant is installed for the purpose of the business of production of textiles, including those dyed, printed or otherwise processed, made wholly or mainly out of cotton, the assessee is entitled to the deduction of the development rebate thereunder. What is important is that this development rebate is available if the machinery or plant is installed for the purposes of the production of textiles, including those "otherwise processed". If the machinery or plant is required to be utilised in the production of such textiles, at whatever stage, the assessee is entitled to the benefit of this development rebate." The Supreme Court in the case of Empire Industries Ltd. & Anr. vs. Union of India & Ors. If the machinery or plant is required to be utilised in the production of such textiles, at whatever stage, the assessee is entitled to the benefit of this development rebate." The Supreme Court in the case of Empire Industries Ltd. & Anr. vs. Union of India & Ors. (supra), has held that processing like bleaching, dyeing and printing is not alien to the concept of "manufacture". It was held that the processing etymologically also meant manufacturing process. In the case of Ujagar Prints vs. Union of India (supra), it was held by Constitution Bench of the apex Court that the retrospective amendments of the definition of "manufacture" in the Central Excises and Salt Act, 1944. The processed article is the article that is produced as a result of such manufacture. The question referred to us, namely, "Whether, on the facts and in the circumstances of the case, the assessee is engaged in manufacture or production of an article as envisaged in s. 32A(2)(b)(iii) of the IT Act and consequently entitled to investment allowance and relief under s. 80J of the IT Act ?" is therefore answered in favour of the assessee and against the Revenue.