Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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ITAT rejected the assessee's claim for deduction under Section 80IA, determining that the appellant did not qualify as a "developer" or "contractor" for infrastructure projects. The tribunal found no evidence of investment in the projects, and the agreements did not impose financial obligations on the assessee. The court emphasized that being a developer requires undertaking entrepreneurial and investment risks, which the assessee failed to demonstrate. Despite being contracted for design and completion work, the assessee could not substantiate the primary conditions for claiming the deduction. Consequently, the tribunal ruled against the assessee's tax benefit claim.
ITAT rejected the assessee's claim for deduction under Section 80IA, determining that the appellant did not qualify as a "developer" or "contractor" for infrastructure projects. The tribunal found no evidence of investment in the projects, and the agreements did not impose financial obligations on the assessee. The court emphasized that being a developer requires undertaking entrepreneurial and investment risks, which the assessee failed to demonstrate. Despite being contracted for design and completion work, the assessee could not substantiate the primary conditions for claiming the deduction. Consequently, the tribunal ruled against the assessee's tax benefit claim.
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