Completion certificate requirement under housing project deduction law barred relief where no local authority certificate was issued.

Deduction under Section 80IB(10) was conditional on compliance with the amended requirement that completion of the housing project be evidenced by a completion certificate issued by the local authority. As no such certificate had been issued for the project, and the record did not show any later issuance, the statutory condition remained unmet. The Tribunal applied the post-amendment requirement for the years under appeal and held that the assessee was not entitled to the deduction.

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Issues: Whether the assessee was entitled to deduction under Section 80IB(10) for the assessment years in question when the completion certificate for the housing project had not been issued by the local authority.

Analysis: The claim for deduction under Section 80IB(10) depended on compliance with the statutory condition, as amended, that completion of the housing project be evidenced by issuance of the completion certificate by the local authority. The project in question had not been issued any completion certificate, and the record did not show subsequent issuance of such certificate. The Tribunal distinguished the earlier pre-amendment position and applied the post-amendment requirement as operative for the years under appeal.

Conclusion: The assessee was not entitled to deduction under Section 80IB(10) for the assessment years under appeal.

Final Conclusion: The housing project deduction was denied because the mandatory completion-certificate condition was not satisfied, and the appeals failed.

Ratio Decidendi: Where the statute makes issuance of the local authority's completion certificate a condition for deduction, non-issuance of that certificate disentitles the assessee to the benefit.

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