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    <title>2022 (1) TMI 1276 - ITAT DELHI</title>
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    <description>An infrastructure contractor was treated as a developer eligible for section 80IA where the substance of the work showed planning, execution, construction and making the facility operational, and recurring facts were unchanged from earlier years. Section 14A disallowance was to be estimated reasonably for years before Rule 8D and recomputed under Rule 8D from assessment year 2008-09 onwards, with no interest disallowance where no interest expenditure existed. Foreign project income and related book-profit treatment under section 115JB were dealt with in line with earlier-year treaty positions. Maintenance provisions, technical know-how expenditure, CSR spend and advances written off were allowed, while prior period expenses required fresh verification.</description>
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