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2013 (9) TMI 1103 - ITAT PANAJIReopening of assessment - deduction u/s 80IB(4) - Held that:- We find that the AO has confirmed that the activities undertaken by the Assessee qualifies to be regarded as manufacture and allowed the claim of the Assessee for A.Y. 2004-05. The principles of consistency would apply and hence it is not open for the Department to question the validity of the allowability of the claim of deduction u/s 80IB(4) for the impugned assessment year by holding that the activities undertaken by the Assessee cannot be regarded as manufacture more particularly when there is no change in the facts and circumstances of the case of the Assessee. This view is supported by the decision of Hon'ble Bombay High Court in the case of CIT vs. Gopal Purohit [2010 (1) TMI 7 - BOMBAY HIGH COURT ].
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