Section 80IA of the Income Tax Act, 1961 – Deduction – Assessee having applied for the occupancy certificate along with architects certificate before the BDA on 29th Dec., 2006 well within the stipulated period of one year. Delay caused by the authority in issuing the occupancy certificate would not obliterate the rights of the assessee to avail the benefit under section 80IA(4). Further the action of the respondent No. 1 CBDT instructing respondent No. 2 Union of India vide official memorandum dt. 1st March ,2012 to withdraw the approval suffers from the vide of arbitrariness and lacks jurisdiction – Softzone Tech Park Ltd vs. CBDT[2020] 312 CTR (Karnataka) 289