Housing project deduction fails where the commercial block exceeds the statutory limit and the project is treated as a single sanctioned unit.

A housing project sanctioned as a single project was ineligible for deduction under section 80IB(10) because the commercial block formed part of the same approved development and its built-up area exceeded the statutory limit. Timely completion of the residential blocks did not cure non-compliance with the commercial-area restriction. A different view taken in another assessment year did not alter the result, as income-tax proceedings are year-specific and res judicata does not apply. The rectification challenge also failed because it depended on the same substantive deduction issue.

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Issues: Whether deduction under section 80IB(10) of the Income-tax Act, 1961 was admissible where the housing project contained a commercial block whose built-up area exceeded the prescribed limit, and whether the allowance in a different assessment year or the rectification proceedings altered that conclusion.

Analysis: The project was approved as a single housing project with residential blocks and a commercial block. The residential blocks were completed within time, but the commercial block formed part of the same sanctioned project and its built-up area exceeded the statutory ceiling. The amended provision requires compliance with the commercial area restriction for eligibility. The fact that another assessment year was dealt with differently did not bind the Tribunal, since income-tax proceedings are assessed year-wise and the principle of res judicata does not apply. The challenge to the rectification order also depended on the same substantive deduction issue.

Conclusion: Deduction under section 80IB(10) was rightly denied, and the assessee's challenge to the rectification order also failed.

Final Conclusion: The Tribunal sustained the disallowance of the housing project deduction and rejected all connected appeals.

Ratio Decidendi: Where a housing project is sanctioned as a single project and the commercial component exceeds the statutory limit, deduction under section 80IB(10) is unavailable notwithstanding timely completion of the residential blocks or a different view taken in another assessment year.

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