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33. We have already spread over the factual matrix in necessary detail with the benefit of the entering of a finding of fact by the Income-tax Appellate Tribunal in regard to the assessment year 1978-79 emphasising its finality. Carefully considering the process, we find that all the nine stages of the process do not show any kind of change or a commercially different commodity is not seen to be passing through the various stages of the process. It cannot be ignored that in common parlance, "coffee" means coffee powder, a beverage consumed as either a hot or cold drink. At no stage, this colour combination between manufacture and production has its manifestation. We have already observed that the entire activity that is to be found from the factual matrix spread over by the Tribunal as a factual situation would not show that the activity can be understood either as manufacture or production in accordance with the law declared in the above four decisions of the apex court. We would like to note that the judgment of the Income-tax Appellate Tribunal dated July 18, 1994, recording the factual situation has been the basis, for the reasons already recorded by us in regard thereto. It is this situation that closes the gates with regard to the finding of fact in regard to the situation, may be with regard to another assessment year. We emphasise this because the finality of the situation rules out any necessity of a remand, again for the same purpose.