Section 80P exemption claim requires fresh Tribunal review after Supreme Court remand and mandate on eligibility conditions.

The Tribunal's rejection of the Revenue's appeal could not stand because the Supreme Court had already remitted the assessee's claim for exemption under Section 80P(2)(a)(i) for reconsideration. That remand required examination of the constitutional documents, return particulars, and the scheme's eligibility conditions, which had not been fully considered earlier. In light of the Supreme Court's binding directions, the Tribunal's order was set aside and the matter was sent back for fresh consideration in accordance with that mandate.

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Issues: Whether the Tribunal's order rejecting the Revenue's appeal could stand in view of the Supreme Court's directions on the assessee's entitlement to exemption under Section 80P(2)(a)(i) of the Income-tax Act, 1961.

Analysis: The earlier Supreme Court decision had remitted the question of exemption for reconsideration, noting that the relevant constitutional documents and return particulars had not been examined and that the eligibility conditions in the scheme required consideration. In view of that binding direction, the Tribunal's order could not be sustained without a fresh examination of the issue in accordance with the Supreme Court's mandate.

Conclusion: The Tribunal's order was set aside and the matter was remitted to the Tribunal for fresh consideration in accordance with the directions of the Supreme Court, in favour of the Revenue.

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