Pure finding of fact sustains housing project deduction; no substantial question of law arose.

The Tribunal's conclusion that the assessee satisfied the conditions for deduction under section 80IB(10) was based on admitted material concerning the chronology and validity of the commencement certificates. The earlier certificates had lapsed, and the later certificate was linked to the earlier cancellation and the clearance process under the Urban Land (Ceiling and Regulation) Act, 1976. The HC treated this as a pure finding of fact, not shown to be perverse or legally erroneous, and held that no substantial question of law arose. The Revenue's challenge therefore failed and the deduction was sustained.

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Issues: Whether the Tribunal's finding that the assessee satisfied the conditions for deduction under section 80IB(10) was perverse or gave rise to any substantial question of law.

Analysis: The Tribunal's conclusion rested on admitted material regarding the chronology and validity of the commencement certificates. The earlier certificates had lapsed or ceased to remain valid after the period for which they were issued, and the later certificate was connected with the earlier cancellation and the clearance process under the Urban Land (Ceiling and Regulation) Act, 1976. On these facts, the Tribunal held that the conditions for availing the deduction were met. The High Court found this to be a pure finding of fact based on the record, not vitiated by perversity or any apparent error of law.

Conclusion: The finding allowing deduction under section 80IB(10) was upheld and no substantial question of law arose.

Final Conclusion: The Revenue's appeal failed because the Tribunal's factual determination on eligibility for the housing project deduction was sustained.

Ratio Decidendi: A pure finding of fact based on admitted material will not raise a substantial question of law unless it is shown to be perverse or legally erroneous.

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