Developer status and documentary rights supported deduction under Section 80IB(10)(d), with no substantial question of law arising.

Deduction under Section 80IB(10)(d) was treated as available where the assessee's agreement and related documents showed rights in the land and responsibility for construction through appointed agents, indicating a developer character rather than a mere contractor. The documentary recitals were treated as conclusive of the assessee's rights, and the Assessing Officer was not permitted to ignore the satisfaction recorded by the statutory authorities. On that basis, no substantial question of law was found in the Tribunal's affirmation of the Commissioner, and the deduction claim succeeded.

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Issues: Whether the assessee was entitled to deduction under Section 80IB(10)(d) of the Income-tax Act, 1961, and whether the Tribunal was justified in holding that the assessee was a developer and not a mere contractor.

Analysis: On scrutiny of the agreement and other material, the assessee was found to have claimed rights in the land and to have executed agreements and appointed agents for construction, showing the character of a developer. The Assessing Officer could not disregard the satisfaction recorded by the statutory authorities, and the documentary recitals were treated as conclusive of the assessee's rights. No substantial question of law arose from the Tribunal's order affirming the Commissioner.

Conclusion: The deduction under Section 80IB(10)(d) was upheld and the assessee's claim succeeded.

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