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    <title>2013 (1) TMI 535 - ITAT HYDERABAD</title>
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    <description>Ownership of land is not decisive for section 80IB(10) relief where the assessee undertakes the project as the real developer and builder, assuming responsibility for approvals, construction, sale, and project risk under a development agreement-cum-GPA. On the facts, the assessee was treated as a developer and builder rather than a mere contractor. Deduction based on work-in-progress and projected profits, however, requires reliable support from sale arrangements, advances, and a sound basis for estimating accrual. As the record did not satisfactorily establish the basis of income recognition, that issue was remitted for fresh examination by the Assessing Officer.</description>
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      <link>https://www.taxtmi.com/caselaws?id=220430</link>
      <description>Ownership of land is not decisive for section 80IB(10) relief where the assessee undertakes the project as the real developer and builder, assuming responsibility for approvals, construction, sale, and project risk under a development agreement-cum-GPA. On the facts, the assessee was treated as a developer and builder rather than a mere contractor. Deduction based on work-in-progress and projected profits, however, requires reliable support from sale arrangements, advances, and a sound basis for estimating accrual. As the record did not satisfactorily establish the basis of income recognition, that issue was remitted for fresh examination by the Assessing Officer.</description>
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