These three appeals have been preferred by Revenue against respective orders of CIT(A) dt. 29th Feb., 2000, 12th March, 2001 and 25th March, 2004 pertaining to asst. yrs. 1997-98, 1998-99 and 2000-01 respectively. All appeals relate to same assessee and solitary issue involved is regarding allowability of deduction under s. 80-IA of IT Act, 1961 (in short Act ). Since appeals relate to same assessee and involve common issue, they have been clubbed and heard together and are being disposed of by way of consolidated order for sake of convenience and brevity. Before us Shri R.K. Goyal learned Departmental Representative appeared f o r Department whereas Shri Krishan Kumar Mehta, learned counsel appeared on behalf of respondent assessee. Their submissions have been considered while disposing of impugned appeals. Since facts are similar for all three assessment years, we take up for discussion facts in relation to asst. yr. 1997-98 to understand controversy on hand. brief facts relevant for purpose of adjudicating dispute before us are as follows. respondent assessee is company incorporated under provisions of Companies Act, 1956 and for asst. yr. 1997-98 it filed return of income declaring income of Rs. 43,40,960 which, inter alia, included claim of deduction under s. 80-IA amounting to Rs. 18,60,412. AO noticed that besides activity of manufacturing of yarn assessee was engaged in trading of raw wool and knitted cloth. That income which has been subjected to claim of deduction under s. 80-IA included profits derived by assessee from trading of raw wool and knitted cloth. According to AO deduction under s. 80-IA of Act was admissible to assessee only in respect to profits and gains derived from business of industrial undertaking. That having regard to meaning of expression Industrial Undertaking only profits and gains derived from activity of manufacture or processing alone was eligible for claim of deduction under s. 80-IA of Act. assessee was thus show caused as to why its claim of deduction under s. 80-IA of Act in relation to incomes derived from trading activity be not denied. Before AO, assessee submitted that it fulfils all conditions required to claim deduction under s. 80-IA of Act inasmuch as gross total income of assessee included profits and gains derived from its industrial undertaking. According to assessee there was no specific requirement under s. 80-IA of Act that only profits derived from manufacturing activity are eligible for deduction under s. 80-IA of Act. In support assessee relied upon judgment of Madras High Court in case of CIT vs. Ashok Leyland Ltd. (1981) 130 ITR 900 (Mad). AO did not accept pleas of assessee. According to AO income may fall within head Business income but insofar as its eligibility for deduction under s. 80-IA is concerned, it is only income derived by assessee from business of industrial undertaking which is eligible for deduction under s. 80-IA of Act. In case of assessee, business of industrial undertaking is to mean activity relating to manufacturing or processing of goods alone. Therefore, profits derived from trading of goods was not eligible to qualify as having been derived from industrial undertaking within meaning of s. 80-IA of Act. AO, therefore, excluded from purview of deduction under s. 80-IA of Act, profits and gains earned by assessee from trading activity. As result eligibility of assessee for deduction under s. 80-IA was scaled down. It is pertinent to note here that upon segregation of profits relating to trading and manufacturing activities, AO computed profits from manufacturing of goods as negative figure i.e., loss. As result, AO held that assessee was not eligible for any deduction under s. 80-IA of Act for year under consideration. assessee challenged decision of AO before CIT(A). In appeal before CIT(A) assessee reiterated its stand that entire profits earned by it which are assessable under head Business were eligible for deduction under s. 80-IA of Act. CIT(A) has since upheld plea of assessee. According to CIT(A) rigours of word derived has been toned down by use of words any business in s. 80-IA of Act, and therefore, trading profits were also eligible for deduction under s. 80-IA of Act provided same are assessable as business income . Against aforesaid decision of CIT(A), Revenue is in appeal before us. Before us learned Departmental Representative Shri R.K. Goyal made Before us learned Departmental Representative Shri R.K. Goyal made brief submissions. According to him, issue in question has since been adjudicated by Hon ble High Court of Punjab & Haryana in case of Liberty Shoes Ltd. (ITA No. 140 of 2005) vide its order dt. 17th Aug., 2006 whereby it has been held that assessee would not be entitled for deduction under s. 80-IA to Act in respect of profits derived from business of trading of goods. Further, learned Departmental Representative pointed out that CIT(A) while deciding issue in favour of assessee has relied upon decision of his predecessor in case of Thapar Fibers (P.) Ltd. which was subject-matter of appeal before Tribunal, who vide its order in ITA No. 411 /Chd/99, dt. 27th May., 2003 has decided issue in favour of Revenue. That, therefore, in view of aforesaid precedents, order of CIT(A) deserves to be set aside and stand of Revenue be upheld. In response learned counsel for respondent assessee Shri Krishan K. Mehta, has made detailed submissions. learned counsel, while fairly not controverting factual matrix brought out by learned Departmental Representative, yet made detailed submissions to demonstrate that phraseology of s. 80-IA stood on different footing than that of erstwhile s. 80-I and having regard to it restrictive meaning of word derived could not be straightaway applied to situation which is covered by section 80-IA of Act. According to learned counsel Revenue does not dispute that assessee is running industrial undertaking. That in view of presence of expressions any profits and gains and any business in section 80-IA(l), it therefore has to follow that all kind of profits and gains earned by industrial undertaking would qualify for deduction under s. 80-IA of Act. Our attention has been drawn to language of s. 80-IA in course of arguments. According to learned counsel due to hanged phraseology of s. 80-IA same has to be taken as more liberal so as to consider within its ambit all business receipts of industrial undertaking. In this regard, more particularly, learned counsel pointed out difference in wording of ss. 80-I and 80-IA as follows. In section 80-I expression used is any profits and gains derived from industrial undertaking "Whereas in section 80-IA expressions used is any profits and gains derived from any business of undertaking". It was therefore emphasized that section 80-IA uses as additional expression that is any business which is not there in section 80-I. According to learned counsel import of such difference is that for purpose of s. 80-IA deduction of tax holiday profits is not merely on profits and gains derived from business of industrial undertaking but profits and gains from any business of such industrial undertaking. use of word any before word business in section 80-IA was sought to be emphasized by learned counsel for assessee. learned counsel also relied upon decision of Amritsar Bench of Tribunal in case of Dy. CIT vs. Chaman Lal & Sons (2005) 93 TTJ (Asr) 132 in support of his submissions. learned counsel also referred to parity of reasoning enunciated by Hon ble Supreme Court in case of Orissa State Warehousing Corpn. vs. CIT (1999) 153 CTR (SC) 177: (1999) 237 ITR 589 (SC) and argued that use of word any enlarge ambit of profits and gains eligible for deduction under s. 80-IA of Act. In reply learned Departmental Representative appearing on behalf of Revenue has contended that judgment of Hon ble Punjab & Haryana High Court in case of Liberty Shoes Ltd. (supra) has considered identical situation whereby it was held that business of trading of goods would not qualify to be held as profits and gains derived from industrial undertaking and thus it was ineligible for deduction under s. 80-IA of Act. We have considered rival submissions carefully. At outset we may state that in view of authoritative decision of Hon ble jurisdictional High Court in case of Liberty Shoes Ltd. (supra), issue before us is liable to be decided against assessee and in favour of Revenue. controversy before us revolves around as to whether or not profits derived by assessee from trading activity would constitute profits and gains derived from industrial undertaking for purposes of s. 80-IA of Act. industrial undertaking of assessee business of sale and manufacture of yarn. stand of assessee is that in view of presence of expression any business profits from all kind of activity, even other than activity of manufacturing carried out by industrial undertaking, would fall within ambit of s. 80-IA of Act. In our view, presence of expression derived from in section 80-IA is crux upon which hinges outcome of present dispute section 80-IA is crux upon which hinges outcome of present dispute before us. meaning of said expression has been subject-matter of consideration of Hon ble apex Court in case of CIT vs. Sterling Foods (1999) 153 CTR (SC) 439: (1999) 237 ITR 579 (SC) and also subsequently in case of Pandian Chemicals Ltd. vs. CIT (2003) 183 CTR (SC) 99: (2003) 262 ITR 278 (SC). import of judgment of apex Court is that expression derived from seeks to cover only receipts derived from actual conduct of business of industrial undertaking. Considered in this light, fact situation in instant case can be deciphered as follows. industrial undertaking of assessee is engaged in manufacture of yarn and its on sale thereof. Additionally, industrial undertaking also derives income by way of purchase and sale of goods manufactured by other concerns and derives income therefrom. Although such trading profits would certainly constitute business income yet it cannot be said to have been derived from business of industrial undertaking, which is of manufacturing of yarn only. stand of assessee was that goods traded in was its raw material for manufacturing process and stock which was not immediately required was sold and resultant profits. That, therefore, such profits be considered as part and parcel of profits derived from business of industrial undertaking. In our view, provisions of s. 80-IA of Act when read as whole do not leave any scope for ambiguity that it is only profits and gains derived from actual conduct of business of undertaking i.e., carrying on of manufacture of production of articles or things which alone are eligible for claim of deduction under s. 80-IA of Act. Moreover, in view of authoritative pronouncement of Hon ble jurisdictional High Court in case of Liberty Shoes Ltd. (supra) it is to be held that deduction under s. 80-IA of Act will not be eligible in respect of profits derived from business of trading of products of other concerns as same does not qualify to constitute profits and gains derived from industrial undertaking. Therefore, having regard to legal position as enunciated by Hon ble jurisdictional High Court in case of Liberty Shoes Ltd. (supra), action of AO deserves to be upheld in denying claim of deduction under s. 80-IA with respect to profits and gains derived by assessee from trading of goods. As result order of CIT(A) is set aside and that of AO is hereby restored. Since facts and circumstances in appeals for asst. yr. 1998-99 i n ITA No. 565/Chandi/2001 and for asst. yr. 2000-01 in ITA No. 639/Chandi/2004 stand on identical footing, our decision in asst. yr. 1997-98 squarely applies in these two appeals also. As result, all appeals of Revenue are allowed. *** JOINT COMMISSIONER OF INCOME TAX v. ARISUDANA SPINNING MILLS LTD.