Ambiguity in "manufacture" definition u/s 10B post-2001 amendment; benefit of doubt favors revenue, not assessee.

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....Disallowance u/s 10B - The term ‘manufacture’ has not been defined in Section 10B after the amendment was carried out in the year 2001. That has created an ambiguity if the argument by the learned Counsel for the assessee is considered where he sought to claim that to grant benefit to the assessee either the definition from the SEZ Act or the export import policy should be considered. The law is now well-settled that in case of ambiguity in an exemption provision the benefit has to go to the revenue. - HC....