Assessee had undertaken a housing project .Date of agreement entered into between assessee and land owner was 11-7-1997. Date of approval of project by local authority was 30-9-1998.  Assessee had incurred certain expenditure like making advances for purchase of land, levelling of land, etc. prior to 1-10-1998  and the said project was completed before 31-3-2008. AO disallowed claim u/s 80IB (10) of the Act . Tribunal allowed deduction holding that assessee had only incurred expenditure like making advances for purchase of land, levelling of land, etc. prior to 1-10-1998 and, therefore, no construction was possible prior to approval of plan by local authority, which was accorded only on 30-9-1998 . On appeal the revenue contended before High Court that since some portion of expenditure for development of project was incurred by assessee prior to cut off date, i.e., 1-10-1998, development work had started prior to cut off date and, therefore, assessee was not entitled to benefit of deduction. High Court held that since expenditure incurred by assessee prior to cut off date of 1-10-1998 was not in nature of development and commencement of housing project itself, accordingly the order of Tribunal is affirmed . (followed  CIT v. Housing & Construction Ltd ( 2014) 225  Taxman 29 (Mag.) (Delhi ) (HC) SLP is granted to revenue ,  ( 2014) 227 Taxman 378 (SC)  ( AY. 2001 -02 )