IN THE HIGH COURT OF BOMBAY AT GOA TAX APPEAL NO. 12 OF 2006 THE COMMISSIONER OF INCOME TAX, ....Appellant PANAJI-GOA. Versus M/S. BHASKAR METALS, PONDA, GOA. ....Respondent Mr. S. R. Rivankar, Advocate for the Appellant. Coram:- DR. S. RADHAKRISHNAN & N. A. BRITTO, JJ. Date:- 3rd October, 2006 P.C.: Heard learned counsel for the Appellant. Perused the Order of the Income Tax Appellate Tribunal. Specially for the reasons stated in paragrphs 5 and 6 of the Order, it is clear that the respondent has been converting granite boulders into metal or chips which obviously amounts to manufacture. If that be so, the respondent is entitled to the benefit under section 80-IA of the I.T. Act. Under the circumstances, we do not find any substantial question of law involved in the present appeal. Appeal stands dismissed. DR. S. RADHAKRISHNAN, J. N. A. BRITTO, J. sl.