Reassessment for thorough verification of manufacturing activity of Assessee not justified

As regards Assessment Years 2007-08 and 2008-09, the notices re-opening the assessment are admittedly within a period of four years. At the same time, a fundamental aspect which must be emphasised is that the first year in respect of which a claim for deduction under section 80IB was made was 2004-05. The claim was allowed. As noted earlier, the re-opening of the assessments for A.Ys. 2005-06 and 2006-07 which are the second and third years has been set aside in the earlier part of this judgement. In consequence, the claim for deduction under section 80IB for A.Ys. 2004-05, 2005-06 and 2006-07...