Sec. 80IB(10) of Income Tax Act, 1961 – Deduction – Revenue filed Appeal against the order of ITAT in allowing the assessee's claim of deduction u/s. 80IB(10) of the Act of Rs. 7,98,48,800/-. The main objection of the Revenue to such claim was that the construction in question was not completed within a period envisaged under the statutory provision and the assessee had developed a project which was not developed by the preceding owners. The Tribunal found that the assessee had merely acquired the right to develop the open land on which previous owner had not commenced the development. High Court dismissed the appeal of the revenue holding that:– The Tribunal has come to factual findings, essentially holding that the assessee had entered into an agreement with the previous Promoters and that the assessee had acquired land along with development rights. Further, that the housing project constructed by the assessee, consisted of building which only included flats. This project was quite different from the project which the previous developer had conceived. The assessee had undertaken development and construction of housing project on a piece of land which was different from the land on which the erstwhile Promoters had completed construction of 40 row houses – YASH ASSOCIATES [2020] 423 ITR 215 (BOM)