Section 206C of the Income-tax Act, 1961—Collection of tax at source—Once the availability of exemption, where the goods are processed for the purposes of trading or selling to the manufacturer or producer of different articles or things therefrom, is ruled out under sub-section (1A) to section 206C, the intention of the Legislature becomes clear to understand the word 'processing', as an intermediary process to qualify the produce, namely, Tendu leaves, for being utilized for the purposes of manufacture or production of articles or things therefrom. It is an integrated process of manufacture or producing bidi in this case, from the processed Tendu leaves, which qualifies for exemption, thus, the processing of Tendu leaves in this case may qualify for the purposes of trading or sale, but not for the utilization for the purposes of manufacture of bidis - GONDIA BEEDI LEAVES CONTRACTORS ASSOCIATION V/s UOI - [2019] 267 TAXMAN 528 (BOM)