JUDGMENT C.N. Ramachandran Nair, J. 1. In the connected appeals filed by the assessee-company the question raised is whether the Income Tax Appellate Tribunal was justified in reversing the order of the first appellate authority by holding that appellant is not entitled to exemption from payment of tax under Section 10B of the Income Tax Act on the profits derived from it's 100% Export Oriented Unit engaged in blending, packing and export of tea bags and tea packets. We have heard Senior counsel Sri.Joseph Vellappally appearing for the assessee-appellant and Senior Standing Counsel Sri.P.K.R.Menon appearing for the respondent- Revenue.