1 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.297 OF 2008 The Commissioner of Income Tax-8 ...Appellant vs. M/s.Natural Gems Ltd. ...Respondent. --- Mr.Suresh Kumar, for appellant. Mr.S.S.Jinsiwala, for Respondent. CORAM: D.K.DESHMUKH & J.P.DEVADHAR, JJ. DATED: 8th August, 2008. P.C.:- 1. Heard the learned Counsel appearing for appellant. It is clear from the order of the tribunal as also the order passed by the appellate authority that both the authorities have considered the activities carried out by the assessee and has 2 recorded the finding of fact that the activities amounts to manufacturing. This is a finding of facts based on the material on record. No question of law arises. Hence, the appeal is rejected. (D.K.DESHMUKH, J.) (J.P.DEVADHAR, J.)