Dismissing the petition  the Court held that the benefit of S.  80IB(10) for slum redevelopment projects was introduced prospectively from 1-4-2005, and the CBDT’s principal notification 67 of 2010 dated 3-8-2010, corrected by Notification No. 2 of 2011 dated 5-1-2011, only aligned the effective date with the statute. Since the legislature never intended retrospective benefit, the impugned corrigendum notification was valid and could not be struck down as ultra vires. Reliance placed on CIT v. Brahma Associates (Bom)HC  and CIT v. Sarkar Builders (2015) 277 CTR 301 (SC) / (2015) 7SCC 579