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    <title>2013 (9) TMI 1090 - ITAT CHENNAI</title>
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    <description>For section 54G, &quot;urban area&quot; was construed by reference to the Central Government&#039;s declaration and the statutory purpose, so Chemmenchery Village was treated as urban and the shifting conditions were found satisfied on the facts of the new unit at Koppur. On road construction expenses, the evidence was doubtful, but complete disallowance was considered excessive because some access work was necessary; a partial estimate was therefore applied. For section 40(a)(i), payments were made to Indian entities for work actually executed by resident contractors with tax deducted at source, so the precondition for invoking withholding-based disallowance was not met.</description>
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      <description>For section 54G, &quot;urban area&quot; was construed by reference to the Central Government&#039;s declaration and the statutory purpose, so Chemmenchery Village was treated as urban and the shifting conditions were found satisfied on the facts of the new unit at Koppur. On road construction expenses, the evidence was doubtful, but complete disallowance was considered excessive because some access work was necessary; a partial estimate was therefore applied. For section 40(a)(i), payments were made to Indian entities for work actually executed by resident contractors with tax deducted at source, so the precondition for invoking withholding-based disallowance was not met.</description>
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