Swarovski India Pvt. Ltd Appeal: The three golden rulings

Advocate Akhilesh Kumar Sah Swarovski India Pvt. Ltd. Vs DCIT (Delhi High Court) 1. While allowing deduction under section 10B, the deduction is to be allowed to eligible undertaking, even the income being in negative. 2. Cutting and polishing of precious and semi precious stones constitutes manufacturing as contemplated in section 10B, 3. No fresh fact or fresh material which formed the reasons to believe for reopening of the assessment except the order passed by the AO, there being no other reason given by the AO for re-opening the assessment, notice issued under section 148 of the Act qu...