Deduction under Section 80IB(10) required remand for de novo assessment due to inadequate AO inquiries and specified directions.

Whether entitlement to a statutory tax deduction required remand for fresh assessment where the Assessing Officer's earlier order was brief and cryptic; the Tribunal applied its prior directions addressing identical facts and held that fundamental factual inquiries were missing. The Tribunal instructed de novo framing of assessment with specified lines of inquiry - ownership and domain over land and project, terms of the development agreement, characterization as work contract, responsibility and possession during construction, engagement of professionals, fund-raising and utilisation, risk and profit allocation - and restored the matter to the Assessing Officer for reconsideration.

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Issues: Whether the claim of deduction under section 80IB(10) requires restoration of the matter to the file of the Assessing Officer for de novo assessment in light of insufficient and cryptic inquiries by the Assessing Officer.

Analysis: The facts in the present assessment year were found identical to those considered in the Tribunal's earlier order for another assessment year, where the Tribunal recorded that the Assessing Officer's order was brief and cryptic and certain fundamental facts necessary for determining entitlement to exemption under section 80IB(10) were not fully brought on record. The earlier order directed remand to the Assessing Officer with specific lines of inquiry including examination of ownership and domain over land and project, terms of the development agreement, whether the arrangement amounted to a work contract, responsibility for project execution, engagement of professionals, procedure for raising and utilization of funds, risk allocation, possession during construction, consideration to landowners and profit sharing, and related financial inquiries. Applying those directions to the identical facts in this appeal, the matter requires de novo framing of assessment by the Assessing Officer with the specified inquiries.

Conclusion: The appeal is restored to the file of the Assessing Officer for de novo consideration after carrying out the inquiries and directions as specified by the Tribunal; the appeal is allowed for statistical purposes in favour of the assessee.

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