Section 80IB(10) completion certificate rule prevails over municipal law, and prior precedent did not support review.

The amended Section 80IB(10) of the Income-tax Act was read to make the local authority's completion certificate the relevant date for completion of construction, and that express Explanation could not be controlled by the Municipal Corporation Act. The cited Supreme Court precedent was held inapplicable because it did not consider such an express statutory explanation. A request for liberty to pursue another remedy could not be granted in review, and differing factual assertions in one petition did not alter the common interpretation already adopted in the main judgment. No ground for review was therefore made out, and the review petitions were liable to be dismissed.

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Issues: Whether the review petitions disclosed any ground for interference on the plea that the Municipal Corporation Act had been overlooked and that the decision was inconsistent with the Supreme Court precedent while interpreting Section 80IB(10) of the Income-tax Act, 1961.

Analysis: The review was directed against the interpretation of the amended provision in Section 80IB(10) of the Income-tax Act, 1961, particularly the Explanation prescribing the completion certificate issued by the local authority as the relevant date for completion of construction. The Municipal Corporation Act could not control or qualify the express language of the amended income-tax provision. The cited Supreme Court decision did not deal with such an express statutory explanation and therefore did not assist the review petitioners. The request for liberty to pursue another remedy could not be granted in review, and the fact situation urged in one petition did not affect the common interpretation already adopted in the main judgment.

Conclusion: No ground for review was made out and the review petitions were liable to be dismissed.

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