Judgment :- R. JAYASIMHA BABU, J. The two questions (1. Whether on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law to hold that the assessee which is a leasing company is entitled to investment allowance on the value of machinery leased out and which was deployed in the business of construction activity ? 2. Whether on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in law in holding that the leasing activity of the assessee would amount to industrial activity for the purpose of grant of investment allowance ?) referred to us concerning the assessment year 1983-84 under the Income-tax Act, 1961, are required to be, and is answered in favour of the assessee and against the Revenue in the light of the decision of the Supreme Court in the case of CIT v. Shaan Finance (P.) Ltd. The assessee is admittedly engaged in the business of leasing of earth-moving equipment. The fact that such earth-moving equipment was utilised in industrial activity was not in dispute. As held by the apex court, it is not necessary in order to claim this allowance, that the assessee himself should be engaged in the manufacture. The fact that the machinery owned by the assessee is leased to manufacturers and used for manufacture is sufficient. The reference is, therefore, answered in favour of the assessee and against the Revenue.