These are appeals against orders of Commissioner made under section 263 of Income-tax Act, 1961 ('the Act') for assessment years 1979-80 and 1980-81. assessee claimed investment allowance under section 32A of Act which was allowed by ITO in assessments made for assessment years 1979-80 and 1980-81. Commissioner was of view that assessment orders are erroneous and prejudicial to interests of revenue and, accordingly, he revised those orders under section 263. He held that assessee is engaged in running automobile workshop. When engine or automobile is entrusted with assessee, it is in disrepair and when it is given back it is fully repaired. Even in commercial sense no new product comes out of alleged manufacturing process. Since no manufacture or production is carried on by assessee, mere obtaining of license on basis that assessee is running industrial undertaking will not be sufficient. No new commercial product comes out of repairing process. Thus, assessee is not entitled to investment allowance. Thus, he directed ITO to withdraw investment allowance granted for assessment years 1979-80 and 1980-81. Against same, assessee has preferred these appeals. 2. learned counsel for assessee submitted that assessee produces new article or thing in its workshop by reboring engine and carrying out various other operations. This amounts to production of article or thing. Thus, assessee is entitled to investment allowance. He place reliance on decisions in CIT v. Perfect Liners [1983] 142 ITR 654 (Mad.) and Singh Engg. Works (P.) Ltd. v. CIT [1979] 119 ITR 891 (All.) learned departmental representative kly urged that no new article or thing is either manufactured or produced by assessee. Hence, no investment allowance could be allowed. It only carries out repair work. He placed reliance on decision in CIT v. N. U. C. (P.) Ltd. [1980] 126 ITR 377 (Bom.). 3. We have considered rival submissions. assessee is engaged in running automobile workshop. assessee does not manufacture or produce any article or thing. engine which had become unusable is rendered usable by subjecting same to certain processing but by that assessee does not manufacture or produce any new article or thing. Thus, in our view assessee is not entitled to investment allowance. 4. In CIT v. Hindusthan Metal Refining Works (P.) Ltd. [1981] 128 ITR 472, Calcutta High Court held that production or manufacture of goods involves bringing into existence new goods or articles known as such goods or articles in market. In that case it was held that process of galvanising does not bring into existence different article or article commonly known to people differently who deal with it before it was galvanised. In Mrs. Daisy Paul v. WTO [1985] 14 ITD 290 (Coch.) assessee was partner in Popular Garage, assessee now under appeal. There is was contended before Tribunal t h t work of reboring carried in Popular Garage will amount to manufacture or producing article or thing. This contention was not accepted by this Bench of Tribunal. It was held that assessee carried on only processing of engine block which had become useless and giving same new life and such activity does not amount to manufacturing or producing any article or thing. But activity of Popular Garage clearly amount to processing of engine as result of which engine which had become unusable becomes useful and gets new lease of life. above orders squarely apply. Thus, in our view, assessee carried only processing activity and is not entitled to investment allowance. decisions relied on by assessee's counsel are distinguishable. decision of Madras High Court in Perfect Liners' case (supra) is case where assessee was engaged in business of purchasing rough castings and supplying same to manufacturers of pumpsets, tractors, etc., after machining and polishing them in its factory. In instant case there is neither any purchase nor sale of any item which is manufactured or produced. Hence, above case has no application. decision of Singh Engg. Works (P.) Ltd's case (supra) has also no application as that is case of manufacture of iron bars and rods out of ingots manufactured from scrap. Thus, we uphold orders of Commissioner made under section 263. 5. In result, appeals fail and are dismissed. *** POPULAR GARAGE v. INCOME TAX OFFICER