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    <title>2012 (4) TMI 563 - ITAT AHMEDABAD</title>
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    <description>The court determined that the assessee qualified as a &quot;developer&quot; rather than a &quot;contractor&quot; for claiming deductions under section 80IA, as it built and operated the infrastructure facility at its own cost. The assessee was found eligible for the deduction, as it was considered the owner of the infrastructure facility based on its investments. The reopening of the assessment under sections 147/148 was deemed valid due to the income escaping assessment. However, the disallowance of expenditure under section 14A was remanded for further determination. The Revenue&#039;s appeals for multiple assessment years were dismissed, while the assessee&#039;s appeals for certain years were allowed for statistical purposes.</description>
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    <pubDate>Mon, 30 Apr 2012 00:00:00 +0530</pubDate>
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      <title>2012 (4) TMI 563 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=170845</link>
      <description>The court determined that the assessee qualified as a &quot;developer&quot; rather than a &quot;contractor&quot; for claiming deductions under section 80IA, as it built and operated the infrastructure facility at its own cost. The assessee was found eligible for the deduction, as it was considered the owner of the infrastructure facility based on its investments. The reopening of the assessment under sections 147/148 was deemed valid due to the income escaping assessment. However, the disallowance of expenditure under section 14A was remanded for further determination. The Revenue&#039;s appeals for multiple assessment years were dismissed, while the assessee&#039;s appeals for certain years were allowed for statistical purposes.</description>
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      <pubDate>Mon, 30 Apr 2012 00:00:00 +0530</pubDate>
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