only question involved in this appeal is whether assessee is entitled to investment allowance under section 32A(2)(a)(iii) of Income-tax Act, 1961 ('the Act') 2. assessee, company, is engaged in business of exhibiting films i n theatres. It has installed machineries such as air-conditioning plant, water pump, projector and screen, electrical fittings, cinema chairs and curtains. In respect of these items, investment allowance of Rs. 50,000 was claimed, which ITO rejected. Commissioner (Appeals) also rejected this claim in appeal by assessee. assessee is renewing its prayer before us by way of this second appeal. 3. Shri Ganesh, learned counsel for assessee, contended that both mechanical and human activity are involved in process of exhibition of films in theatres and that sound and visual image produced in process of exhibition should be taken as 'article' or 'thing' within meaning of section 32A(2)(a)(iii). It was also his argument that 'article' or 'thing' is not defined either in Act or any other statute and that dictionary meaning of these two terms is wide enough to include image produced on screen coupled with sound effect when film is projected. We shall advert to case law relied upon by him little later, when we get into discussion. 4. Shri Mahadeshwar, learned departmental representative, contended that image on screen, which is nothing but illusion does not have any physical existence and that 'article' or 'thing' necessarily as to be property capable of marketability since these words are used in context of industrial undertaking. It was also his argument that cinematographic films and projectors, included in Eleventh Schedule, of Act, having been themselves excepted from operation, rub-clause (iii) of section 32A(2)(b), momentary entertainment given to audience by visual and sound effect cannot certainly be considered as 'article' or 'thing' though dictionary meaning of these expressions may have wider dimension in different contexts. 5. dictionary meaning of word 'produce', no doubt, includes 'to bring forth; to exhibit'; and on that basis, it may perhaps be possible to say that image synchronised with sound system is produced on screen. For being eligible to investment allowance under provision under consideration, it must be industrial undertaking engaged in business of 'manufacture or production of any article or thing', leaving away business of construction, which is not pertinent for this case. We may here alone say that exhibition of films in theatre is not 'engaged in business of manufacture' in view of what has been stated by Supreme Court in Union of India v. Delhi Cloth & General Mills Co. Ltd. AIR 1963 SC 791. Their Lordships said: "........The word 'manufacture' used as verb is generally understood to mean as 'bringing into existence new substance' and does not mean merely 'to produce some change in substance', however minor in consequence change may be. This distinction is well brought about in passage thus quoted in Permanent Edition of Words and Phrases, Vol. 26, from American Judgment. passage runs thus: 'Manufacture' implies change but every change is not manufacture and yet every change of article is result of treatment, labour and manipulation. But something more is necessary and there must be transformation; new and different article must emerge having distinctive name, character or use." (p. 794) 6. What remains for discussion is whether assessee is engaged in activity of producing any 'article' or 'thing'. No doubt, machinery such as projector is used and human element is also involved in projection of film. Projection, no doubt, produces both sound and light effect which constitutes entertainment to audience. What is of saleable value here is element of enjoyment or entertainment and not image or sound effect as such. It cannot be denied that no article or thing which can be equated to property of physical nature is acquired by person who experiences enjoyment. 7. On behalf of assessee, our attention was invited to decision of Supreme Court in Christian Mica Industries Ltd. v. State of Bihar [1961] 12 STC 150 to contend that dictionary meaning of word 'production' had been adopted in dealing with case under Bihar Sales Tax Act, where that expression had not been statutorily defined and that we would be justified in adopting same course in understanding 'production' used in section 32A as this has not been statutorily defined in Act. 8. Aluminum Corpn. of Indian v. Coal Board AIR 1967 Cal. 222 was another case cited to say that it is not necessary that some goods should be manufactured in sense that raw material should be used to turn out something altogether different and that it is enough if human activity is spent on something which may be subjected to process in order that something else is brought out. To repeat, attempt of Shri Ganesh had been that human element involved in projecting film with help of projector to bring about vision and sound effect for benefit of audience is sufficient to say that 'article' or 'thing' is produced. 9. It was also point of Shri Ganesh that 'article' or 'thing' need not be corporeal property and that even incorporeal property such as copy-right could be goods as pointed out by Madras High Court in A.V. Meiyappan v. CCT [1967] 20 STC 115. 10. Elaborating his argument, Shri Ganesh contended that phrase 'manufacture or produce articles' by industrial undertakings is also used in section 80J of Act and that benefit thereunder has been extended to cases where human agency is associated with natural processes such as hatching of eggs by mechanical process which are said to have produced article or thing and, to illustrate, decision of Tribunal in case of Venkateswara Hatcheries (P.) Ltd. [IT Appeal Nos. 290 and 291 (Hyd.) of 1981] was relied upon. 11. We have given our fullest thought to matter and, in our view, assessee cannot be said to be industrial undertaking engaged in production of article or thing. It is not sufficient if merely assessee is producing something capable of being felt by perception of eye and ear; but whether article or thing has resulted in projection of films. case law relied upon by Shri Ganesh does not readily help us for they take us no further than to show that assessee is producing picture effect on eye synchronised with sound effect. We must note here that both in A.V. Meiyappan's case (supra) and Aluminium Corpn. of India's case (supra), where wider meaning was ascribed to word 'produce', result of business carried on by those sales tax assessees was to produce some physical substance. It is true that incorporeal right could also be property in some context. But here we are concerned with industrial undertaking and by no stretch of imagination or argument, projection of films in theatre could be said to be industrial undertaking. Photo copying or zeroxing is held not to involve any industrial activity by Tribunal, Bombay Bench in case of ITO v. Daks Copy Services (P.) Ltd. [1984] 8 ITD 245, we may also usefully refer to decision of Tribunal, Ahmedabad Bench in case of New Indian Textile Products v. ITO [1982] 1 ITD 837 where development rebate had been claimed more or less on similar situation and following stated therein is worth of note: "The meaning given to word 'process', relied upon by assessee, was not appropriate in context of taxation statute dealing with definition of 'industrial company', which emphasises two aspects, namely, manufacture of goods or processing of goods. Processing involves certain changes in goods produced and no such change occurs when film is exhibited qualitatively by projecting it on screen except wear and tear caused by its use. Thus, mere use of goods as in this case cannot amount to processing of goods. Accordingly assessee's claim for being treated as industrial company had been correctly rejected by lower authorities." (p. 838) 12. As section 32A is designed to give relief in certain cases of business venture, article or thing for being eligible for investment allowance under said provision must be property capable of marketability. Assuming that entertainment is subject of sale to person who enjoys film, there is nothing which he in turn could sell to others and, thus, it is clear that there is no subject-matter of saleable value. 'Article' or 'thing' must be property capable of sale and nature of activity carried on by assessee does not answer to this description. We are, therefore, of view that there authorities below were right in rejecting claim for investment allowance and assessee, in our opinion in rejecting claim for investment allowance and assessee, in our opinion too, is not eligible for this benefit. 13. In result, appeal is dismissed. *** FIDA FILM & HOTEL CO. (P) LTD. v. INCOME TAX OFFICER