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The assessment u/s 143(3) was completed, disallowing the deduction u/s 10B on grounds that processing iron ore does not constitute manufacturing within Section 10B's meaning and the Amona and Chitradurga units were not new units. The Tribunal allowed the Section 10B deduction claim. The High Court held that reopening assessment to disallow Section 10B deduction based on survey evidence cannot be permitted as it violates Section 147's third proviso. The assessee's claim for Section 10B deduction from export-oriented undertakings at Amona, Chitradurga, and Codli was adjudicated in original assessment proceedings. Reassessing to disallow the deduction again exceeds jurisdiction. The Court ruled in the assessee's favor.
The assessment u/s 143(3) was completed, disallowing the deduction u/s 10B on grounds that processing iron ore does not constitute manufacturing within Section 10B's meaning and the Amona and Chitradurga units were not new units. The Tribunal allowed the Section 10B deduction claim. The High Court held that reopening assessment to disallow Section 10B deduction based on survey evidence cannot be permitted as it violates Section 147's third proviso. The assessee's claim for Section 10B deduction from export-oriented undertakings at Amona, Chitradurga, and Codli was adjudicated in original assessment proceedings. Reassessing to disallow the deduction again exceeds jurisdiction. The Court ruled in the assessee's favor.
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