Section 80P deduction dispute sent back for fresh assessment after facts were found insufficiently recorded.

Disallowance of deduction under section 80P(2)(a)(i) was not interfered with on the existing record because the relevant factual matrix did not clearly emerge from the assessment order. The matter was therefore considered fit for fresh examination by the Assessing Officer, with liberty to the assessee to adduce evidence and with directions to provide a reasonable opportunity of hearing. The issue was restored for de novo assessment in accordance with law.

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Issues: Whether the disallowance of deduction claimed under section 80P(2)(a)(i) required interference, and whether the matter should be restored to the Assessing Officer for fresh assessment.

Analysis: The relevant factual matrix was not ly emerging from the assessment order. Since the material facts were not adequately brought out, the issue was considered fit for fresh examination by the Assessing Officer, with liberty to the assessee to adduce evidence and with directions to provide reasonable opportunity of hearing.

Conclusion: The issue was restored to the Assessing Officer for de novo assessment in accordance with law.

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