Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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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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