( 1 ) THE Tribunal, Delhi, has referred the following question of law under Section 256 (1) of the IT act, 1961 (hereinafter referred to as the Act) for opinion to this Court : whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the appellant was not entitled to investment allowance under Section 32a of the IT act, 1961 in respect of the plant and machinery of its cold storage ? ( 2 ) HEARD Sri Rishi Raj Kapoor, learned Counsel for the assessee and Sri Shambhoo Chopra, learned standing counsel for the Revenue. ( 3 ) THE reference relates to the asst. yr. 1982-83. ( 4 ) THE applicant owns a cold storage. It has claimed investment allowance under Section 32a of the IT Act. The claim has been disallowed by the assessing authority, which order has been upheld upto the stage of the Tribunal. In view of the decision of this Court [sic-the Supreme court] in Delhi Cold Storage (P) Ltd. v. CIT AIR1991 SC 2125 , [1991 ]72 Compcas723 (SC), (1991)3 Complj131 (SC), [1991]191 ITR656 (SC), JT1991 (3)SC 449 , 1991 (2)SCALE346 , (1991)4 SCC239 , [1991]3 SCR589 , the cold storage is not entitled for investment allowance in respect of plant and machinery installed for running the business of cold storage as it is not engaged in the business of manufacture or processing any new articles. ( 5 ) IN view of the above, we answer the question referred to us in affirmative, i. e. , in favour of the revenue and against the assessee. There shall be, however, no order as to costs. . .