Reopening of assessment u/s 147 - denial of deduction u/s 80IB -...

Reopening of assessment u/s 147 - denial of deduction u/s 80IB - there were deliberations on the very issue as to whether the activity undertaken by the petitioner amounted to manufacture or not before the respective assessment orders were passed for the respective Assessment Years by the respondent’s predecessor. - Reopening of the assessment to deny the deduction under Section 80IB is therefore without jurisdiction.