1. dispute in this appeal is against disallowance of assessee's claim for investment allowance of Rs. 15,238. assessee is clinical biochemist. He invested Rs. 60,954 for purchase of laboratory equipment used in practice of his profession. He claimed investment allowance with respect to said laboratory equipment. It was urged that it is with aid of plant and machinery purchased by assessee for Rs. 60,954 he is able to produce slides of blood specimens and different cultures such as urine culture, etc. Thus, assessee produces article or thing and he satisfies conditions laid down under section 32A of Income-tax Act, 1961 ('the Act'), for allowing investment allowance. ITO did not accept this submission. He held that machinery used will not come under category of plant and machinery used for production of any article or thing. machinery used by him is only to examine blood, urine, etc., and diagnose nature of disease. Thus, he rejected claim for investment allowance. On appeal AAC upheld disallowance. Against same assessee has filed present appeal. 2. learned counsel for assessee kly urged that assessee produces article or thing by way of slides of blood specimens and different cultures such as urine culture, etc. Thus, assessee satisfies condition under section 32 of Act. Hence, investment allowance should be allowed. In this connection he placed reliance on order of Tribunal in First ITO v. Dr. P . Vittal Bhat [1983] 6 ITD 560 (Bang.) (SB) and two decisions of Madras High Court in Dr. P. Vadamalayan v. CIT [1969] 74 ITR 94 and CIT v. Dr. V. K. Ramachandran [1981] 128 ITR 727. learned departmental representative kly urged that assessee only tests blood group and urine, etc. Thus, it cannot be said that he produces article or thing. Thus, assessee does not satisfy these conditions laid down in section 32A. 3. I have considered rival submissions. assessee is clinical bio- chemist. He takes blood or urine from patients and prepares slides of culture and examines blood or urine and gives his report. In this process he neither manufactures nor produces any article or thing. conditions laid down in section 32A have not been satisfied. Hence, assessee is not entitled to investment allowance. decision of Madras High Court in Dr. V. K. Ramachandran's case (supra) and order of Tribunal in case of Dr. P. Vittal Bhat (supra) are cases of X-ray units where X-ray film is exposed and X- ray photograph is produced which is different and distinct article from raw film. Thus, there is production of new article. Those case have no application to instant case as assessee does not manufacture or produces any article or thing. decision of Madras High Court in case of Dr. P. Vadamalayan (supra) has also no application to instant case as that is case of nursing home. Thus, in my view, lower authorities were justified in disallowing claim for investment allowance. 4. In result, appeal fails and is dismissed. *** DR. P.S. PARGONKAR v. INCOME TAX OFFICER