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Giving the above meaning it would be seen that in the case of the assessee the end-product is a tunnel or a power house or a dam. In our opinion, a tunnel or a power house or a dam cannot be considered to be 'articles' as the reference in the section appears to be an independent commodity. From that angle, we find that the assessee-company was not manufacturing or producing articles. If all the intermediate products were eligible for deduction under Section 80J, the question would arise as to when such undertaking starts being eligible for the relief under Section 80J. A company may start making out slabs in one year and the other small structural components in another year and may ultimately construct the dam in the third year. If the ultimate product is to be considered the undertaking could not be eligible in the first two years and in the third year when the ultimate product comes into existence, it is found that it is not an article, as it is an immovable property. We are not inclined to take the view that the making of tunnel or dam can also be considered as a manufacture of articles. While we do so, we respectfully depart from the decision of the Orissa High Court in the case of N.C. Budharqja & Co. (supra). Section 80J has to be considered as a whole and when we look to its requirements, we find that an undertaking like the assessee cannot get the benefit under Section 80J as it stands. In the course of making of dams or tunnels, the assessee may acquire various raw materials and may process them to construct the dam. In that process it is likely that some components are manufactured by undertaking itself. That will be an intermediate product. However, it cannot result in the conclusion that the undertaking is manufacturing articles for which it has come into existence. If each intermediate articles was to be taken into consideration, there will be no end to the confusion of computation or grant of relief. In fact, Section 80J does not contemplate such a meaning. It has, therefore, to be held that the assessee-company in its undertaking for the construction of tunnels or dams is not manufacturing or producing articles so as to enable it to get deduction under Section 80J. The same position will apply to the claim of the assessee under Section 80HH. The language there is also similar to the language used in Section 80J.