assessee is aggrieved of order dated 14-3-1983 of learned Commissioner (Appeals). 2. assessee, Budhwar Cold Storage, Ujhani, Budaun is unregistered firm. assessee claimed investment allowance of Rs. 66,148 under section 32A of Income-tax Act, 1961 (' Act ') at rate of 25 per cent on machinery and plant worth Rs. 2,64,554. assessee claimed before ITO that cold storage involved manufacturing. However, ITO held that cold storage only involved processing and not manufacture or production of article or thing. Therefore, claim of investment allowance was disallowed. Since industrial undertaking, in question, is situated in backward district, deduction under section 80HH of Act was also claimed by assessee. assessee did not file prescribed audit report in Form No. 10C, as required under section 80HH(5), read with rule 18B of Income-tax Rules, 1962 (' Rules ') and, therefore, claim was rejected by ITO. first two grounds of appeal relate to these claims. In appeal, learned Commissioner (Appeals) upheld rejection of claims. 3. In further appeal before us, Shri K.L. Goel, learned counsel for assessee, placed reliance on following decisions---CIT v. Kanodia Cold Storage [1975] 100 ITR 155 (All.), Addl. CIT v. Farrukhabad Cold Storage (P.) Ltd. [1977] 107 ITR 816 (All.), Farrukhabad Cold Storage (P.) Ltd. v. CIT [1979] 119 ITR 895 (All.) and CIT v. Yamuna Cold Storage [1981] 129 ITR 728 (Punj. & Har.). He also relied upon definition of ' manufacturing process ' in section 2(k) of Factories Act, 1948, and particularly drew our attention to Factories (Amendment) Act, 1976, by which new sub-clause (vi) was added to section 2(k) in following terms: ' (vi) Preserving or storing any article in cold storage '. On other hand, Shri S.D. Kapila, learned departmental representative, kly supported orders of income-tax authorities. In particular, he pointed out that Factories Act would be relevant only for purposes of factory building. He pointed out that in section 80J(4) of Act since specific reference was made to cold storage plant, which did not find mention in section 32A or 80HH, it was clear indication that relief under section 32A or section 80HH was not intended to be given in cases of cold storage. He also pointed out that when potatoes were kept in cold storage, they were only preserved and that neither did they undergo any transformation, nor did commercially different article or thing resulted by putting them in cold storage. He submitted that none of decisions, referred to on behalf of assessee, was of assistance to it. 4. We have considered rival submissions as also decisions, referred to above. Section 32 of Act, which deals with depreciation, uses expression ' plant '. Section 43(3) of Act defines ' plant '. It is with reference to said definition that it was held by Hon'ble Allahabad High Court in case of Kanodia Cold Storage that freezing chamber with insulated walls in cold storage amounted to ' plant ' which was entitled to depreciation at rate of 15 per cent on its written down value. It does not help assessee as this is not point in issue before us. Section 2(7)(d) of Finance Act, 1966 and Finance (No. 2) Act, 1967, defined ' industrial company ' as company which was mainly engaged in business of generation or distribution of electricity or any other form of power or in construction of ships or in manufacture or processing of goods or in mining. It is with reference to said definition that it was held by Hon'ble Allahabad High Court in case of Farrukhabad Cold Storage (P.) Ltd. that company doing cold storage business answered description of industrial company, so defined. This again is not point at issue before us. Again, in latter case of Farrukhabad Cold Storage (P.) Ltd., decided by Hon'ble Allahabad High Court, question examined was whether assessee was ' priority industry ' under section 80-I of Act on ground that it was engaged in activity of production of processed seed within meaning of section 80B(7), read with item (28) of Sixth Schedule of Act. It was held that processing of seed was different from keeping of potatoes in cold storage and that even if keeping or preservation of potatoes in cold storage amounted to ' processing ', it would not amount to assessee's engagement in production of processed seeds as potatoes could be used for multifarious purposes. Here also, question dealt with and answered by Hon'ble High Court was not under section 32A or 80HH. In case of Yamuna Cold Storage, again, though cold storage was held to be factory under Factories Act, Hon'ble Punjab and Haryana High Court was only considering meaning of ' plant ' under section 43(3) with reference to thermocole insulation. It was held that as factory building, building of cold storage was entitled to depreciation at rate of 15 per cent. That is how definition of ' manufacturing process ' under Factories Act, as amended by Factories (Amendment) Act, 1976 does not assist assessee on facts of present case. We have to see whether, on wordings of sections 32A and 80HH, assessee was entitled to investment allowance and deduction. Here, it will be noticed that section 32A uses expression ' business of manufacture or production of any article or thing '. expression used in section 80HH is similar, namely, ' to manufacture or produce articles '. There is no reference to processing as used in definition of ' industrial company ' under section 2(7)(d) of Finance Act, 1966, and Finance (No. 2) Act, 1967. There is force in submission made on behalf of department that unlike section 80J(4)(iii), reference is not made in section 32A or 80HH regarding ' operation of cold storage plant '. This would show that mere processing (even if potatoes were held to undergo processing in cold storage) is not recognised under sections 32A and 80HH to amount to manufacture or production of any article or thing. same expression is used in sections 80HHA and 80-I(2)(iii) of Act. There is another factor also which we may mention in passing. Section 35C of Act, which deals with agricultural development allowance, refers to company or co-operative society being engaged in manufacture or processing of any article or thing which is made from or used in such manufacture or processing as raw material, any product of agriculture, animal husbandry or dairy or poultry farming. As already noticed above, neither section 32A, nor section 80HH refers to processing of any article or thing. Viewed in this context, we are of view that income-tax authorities were quite justified in not upholding claims of assessee under sections 32A and 80HH as assessee did not satisfy requirements of these provisions. 5 to 10. [These paras are not reproduced here as they involve minor issues.] 11. last ground relates to disallowance out of expenses for maintenance of vehicles. ITO disallowed Rs. 2,270 out of expenses of maintenance of vehicles. ITO disallowed Rs. 2,270 out of expenses of maintenance of vehicles, amounting to 50 percent of expenditure. In appeal, learned Commissioner (Appeals) reduced disallowance to one-fourth of expenditure. Here also, we see no reason to interfere as user of vehicles for personal purposes is not under dispute and extent of disallowance seems to be reasonable. 12. In result, appeal filed by assessee is only partly allowed, as above. *** BUDHWAR COLD STORAGE v. INCOME TAX OFFICER