Judgment K. Raviraja Pandian, J. The assessee filed these appeals against the order of the Income Tax Appellate Tribunal, Chennai Bench "C", made in I.T.A. Nos.2151 to 2153/Mds/06 dated 12. 2007. 2. The material facts culled out from the statement of facts stated in the memorandum of appeals are as follows:-The appellant/assessee is a partnership firm engaged in the business of manufacturing photographic film and photographic paper. The photographic films are manufactured out of jumbo rolls of films/pancakes by an elaborate manufacturing process. The appellant/assessee is also manufacturing photographic paper, which is obtained by cutting, sizing and packing smaller sizes of photographic paper from jumbo rolls of photographic paper. The assessee claimed relief and was granted relief under Section 80IB of the Income Tax Act in respect of assessment years upto 2002-03. But, subsequently, the assessing authority revised the earlier assessment and in the assessment, for the assessment years 2003-04 to 2005-06, disallowed the claim for relief u/s.80IB on the ground that the activity carried on by the assessee both in regard to photographic papers and photographic films do not constitute manufacture or production of an article or thing entitling it to relief u/s.80IB. On appeal, the assessees appeals were negatived by the Commissioner of Income-Tax Appeals and further appeals to the Sales Tax Appellate Tribunal were also decided against the assessee. Hence the present appeals at the instance of the assessee by framing the following substantial questions of law? (a) Whether on facts and in the circumstances of the case, the Tribunal is right in holding that the appellant is not eligible for relief under Section 80IB of the Income Tax Act? (b) Whether on the facts and in the circumstances of the case, the Tribunal is right in holding that the manufacture of photographic papers and the manufacture of photographic film rolls involve identical activities and whether in the light of the material evidence produced before the Tribunal, the Tribunal is justified in coming to the aforesaid conclusion? (c) Whether on the facts and in the circumstances of the case, the Tribunal is right in rejecting the appellants prayer for an inspection of the factor to assess the actual nature of the activities involved? and (d) Whether on the facts and in the circumstances of the case, the disallowance of relief under Section 80IB in respect of the income assessed under the head "other sources"? 3. and (d) Whether on the facts and in the circumstances of the case, the disallowance of relief under Section 80IB in respect of the income assessed under the head "other sources"? 3. We have heard the learned counsel on either side and perused the materials place on record. 4. The issue as regards the activity of converting jumbo rolls of photographic films into marketable small size photographic paper has been considered by this Court in Commissioner of Income-Tax v. Computer Graphics Limited reported in (2006) 285 ITR 84). In the case of India Cine Agencies v. Commissioner of Income-Tax reported in (2003) 261 ITR 491), it has been held that in spite of sophisticated machinery having been used, the product imported in jumbo rolls of photographic films, and the conversion of the same into marketable small size photographic paper, cannot be regarded as manufacturing activity. This judgment has been taken on appeal to the Supreme Court and the Supreme Court, in the decision of India Cine Agencies v. Commissioner of Income-Tax reported in (2009) 308 ITR 98 (SC) has held that the word "production" or "produce" when used in juxtaposition with the word "manufacture" takes in brining into existence new goods by a process, which may or may not amount to manufacture. It also takes in all the by-products, intermediate products and residual products, which emerge in the course of manufacture of goods and thus, reversed the finding recorded by this Court in the decision reported in India Cine Agencies v. Commissioner of Income-Tax (2003) 261 ITR 491). 5. In view of the above, questions of law 1 to 3 framed in these appeals have to be answered in the negative, in favour of the assessee and against the Revenue and are answered accordingly. 6. 5. In view of the above, questions of law 1 to 3 framed in these appeals have to be answered in the negative, in favour of the assessee and against the Revenue and are answered accordingly. 6. The 4th question of law, however, was held against the assessee by the Supreme Court in the case of Pandian Chemicals Ltd. v. Commissioner of Income-Tax reported in (2003) 262 ITR 278), whereby the decision of this Court in Commissioner of Income-Tax v. Pandian Chemicals Ltd. reported in (1998) 233 ITR 497 (Mad.) has been affirmed by holding that the interest derived by the industrial undertaking of the assessee on deposits made with the Electricity Board for the supply of electricity for running the industrial undertaking could not be said to flow directly from the industrial undertaking itself and was not profits or gains derived by the undertaking for the purpose of the special deduction under Section 80HH. Hence, the 4th question of law has to be answered in the affirmative, against the assessee and in favour of the Revenue and is answered accordingly. 7. In the result, the tax case appeals are disposed of in the above manner. No costs. Consequently, connected miscellaneous petitions are closed.