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    <title>2025 (4) TMI 1661 - ITAT AHMEDABAD</title>
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    <description>ITAT Ahmedabad addressed two issues: deduction under section 80IA and TDS disallowance under section 40(a)(ia). The assessee claimed 80IA deduction for road development work but AO denied it, stating failure to satisfy conditions as the assessee was a sub-contractor, not developer. ITAT noted the assessee was assigned work by NHAI and performed development functions, making it eligible as developer. However, due to unclear payment arrangements between NHAI, assessee, and main contractor, ITAT remanded the matter to AO for verification of actual payment flows to prevent double claims. The TDS disallowance issue was also remanded for fresh consideration with proper hearing opportunity.</description>
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      <title>2025 (4) TMI 1661 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=462667</link>
      <description>ITAT Ahmedabad addressed two issues: deduction under section 80IA and TDS disallowance under section 40(a)(ia). The assessee claimed 80IA deduction for road development work but AO denied it, stating failure to satisfy conditions as the assessee was a sub-contractor, not developer. ITAT noted the assessee was assigned work by NHAI and performed development functions, making it eligible as developer. However, due to unclear payment arrangements between NHAI, assessee, and main contractor, ITAT remanded the matter to AO for verification of actual payment flows to prevent double claims. The TDS disallowance issue was also remanded for fresh consideration with proper hearing opportunity.</description>
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