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Deduction under section 80IA(4) was allowed because the railway signalling contracts involved design, drawings, procurement, fabrication, erection, installation and commissioning of infrastructure, followed by transfer to the Railway authorities. On that factual basis, the assessee was treated as a developer of an infrastructure facility and not as a mere works contractor, so the statutory conditions for the deduction were satisfied. The Tribunal also relied on binding earlier decisions in the assessee's own case and the jurisdictional High Court's affirmation on identical facts, holding that judicial consistency required the same relief to continue for the later year. The Revenue's appeal was dismissed.
Deduction under section 80IA(4) was allowed because the railway signalling contracts involved design, drawings, procurement, fabrication, erection, installation and commissioning of infrastructure, followed by transfer to the Railway authorities. On that factual basis, the assessee was treated as a developer of an infrastructure facility and not as a mere works contractor, so the statutory conditions for the deduction were satisfied. The Tribunal also relied on binding earlier decisions in the assessee's own case and the jurisdictional High Court's affirmation on identical facts, holding that judicial consistency required the same relief to continue for the later year. The Revenue's appeal was dismissed.
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