Dismissing the appeal of the revenue the Court held that a plain reading of section 8IB(10) of the Income-tax Act, 1961, makes it clear that deduction is available in a case where an undertaking develops and builds a housing project. The section clearly draws the distinction between “developing” and “building”. An assessee who is only an owner of the land and has outsourced the work of construction of the building and had realised the sale proceeds in the form of constructed area is entitled to deduction under section 80IB. Followed CIT v. Veena Developers (2018) 12 ITR-OL 487 (SC) (AY 2006-07 to 2009-10)