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    <title>2025 (2) TMI 285 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai dismissed assessee&#039;s claim for deduction under Section 80IA, holding that the assessee functioned as a contractor for tunnel design and construction, not as an infrastructure developer. The tribunal found that LMRCL, being a special purpose vehicle incorporated under Companies Act with 50:50 equity between Central and State Government, did not qualify as Central/State Government or local/statutory authority as required under Section 80IA(4). However, ITAT allowed deduction of legal and professional fees paid to Gulemark TPL JV under Section 37, ruling these were legitimate business expenses. Revenue&#039;s appeals were dismissed.</description>
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    <pubDate>Wed, 29 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (2) TMI 285 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=765739</link>
      <description>ITAT Mumbai dismissed assessee&#039;s claim for deduction under Section 80IA, holding that the assessee functioned as a contractor for tunnel design and construction, not as an infrastructure developer. The tribunal found that LMRCL, being a special purpose vehicle incorporated under Companies Act with 50:50 equity between Central and State Government, did not qualify as Central/State Government or local/statutory authority as required under Section 80IA(4). However, ITAT allowed deduction of legal and professional fees paid to Gulemark TPL JV under Section 37, ruling these were legitimate business expenses. Revenue&#039;s appeals were dismissed.</description>
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