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3. The appellants' reply was that they had not manufactured industrial fan. Their plea was:-

(a) They are a team of technocrats and were working as a designing and trading organisation carrying out their business activities at their office premises; they do not manufacture any goods in their premises; that they had specialised in designing humidification systems for textile mills; that taking into account the factors viz. the machine load, lighting load, roof specifications, false ceiling specification and we bulb (sic) temperature, basic drawings for setting up a humidification plant house are supplied; and that the above basic engineering data was later translated by Civil Architects/structural engineering into Civil drawings and designs and working drawings.