Section 80IB(10) deduction for shop sale profits held available, while the later commercial-unit amendment was prospective.

Deduction under Section 80IB(10) was held available on profits derived from sale of shops for the relevant period, as the provision was construed not to restrict relief only to residential units in the manner urged by the Revenue. The later amendment inserting clause (d), which addressed shops and commercial establishments, was treated as prospective and did not apply retrospectively. The issue was therefore answered in favour of the assessee and against the Revenue, consistent with the Court's view in a connected decision.

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Issues: Whether deduction under Section 80IB(10) of the Income-tax Act, 1961 was available in respect of profit derived from sale of shops and whether the amendment introducing clause (d) applied retrospectively.

Analysis: The question of law had already been answered by the Court in a connected decision, and the parties agreed that the same answer governed the present appeals. The statutory provision was construed as not restricting the benefit only to residential units in the manner suggested by the Revenue for the relevant period, and the later amendment concerning shops and commercial establishments was treated as prospective.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

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