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T.N.C. Rangarajan, Judicial Member

1. This appeal relates to the claim of the assessee for investment allowance under Section 32A of the Income-tax Act, 1961. The admitted facts are that the assessee is engaged in the business of the data processing. The services are rendered mainly for M/s. Quality Biscuits Co. For that purpose, the assessee had purchased a computer for Rs. 4,61,760 and claimed investment allowance of Rs. 1,15,429 thereon. The Income-tax Officer on the directions of the Inspecting Assistant Commissioner held that data processing did not involve construction, manufacture or production of any article or thing so as to fulfil the conditions required under Section 32A for being eligible for the investment allowance. On appeal, the Commissioner (Appeals) also rejected the claim in the same view.