The assessee claimed deduction in respect of special reserve under section 36(1)(viii) of the Act. The Assessing Officer disallowed the claim of the assessee holding that the assessee had not advanced any loan as long-term finance for development of housing in India, industrial or agricultural development or development of infrastructure facility in India. CIT(A) held that the construction/purchase of individual houses does not tantamount to housing development. Hence, he upheld the action of the Assessing Officer insofar as the disallowance of the claim of the assessee for advances given for development of housing is concerned under section 36(1)(viii). Tribunal  affirmed the  order of CIT(A). (AY. 2012-13)