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    <title>2026 (1) TMI 480 - SC Order</title>
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    <description>Deduction under s. 80-IA(4) turned on whether the assessee executed works as a mere contractor or developed eligible infrastructure facilities. The HC affirmed the ITAT&#039;s finding that, on the nature of obligations and role in executing the project, the assessee functioned as a developer and not as a contractor, and therefore qualified for s. 80-IA(4) relief; the disallowance was rightly deleted. Before the SC, the special leave petition was filed with an unexplained 358-day delay and the precedent relied upon had attained finality; consequently, the SLP was dismissed on delay as well as on merits.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784724</link>
      <description>Deduction under s. 80-IA(4) turned on whether the assessee executed works as a mere contractor or developed eligible infrastructure facilities. The HC affirmed the ITAT&#039;s finding that, on the nature of obligations and role in executing the project, the assessee functioned as a developer and not as a contractor, and therefore qualified for s. 80-IA(4) relief; the disallowance was rightly deleted. Before the SC, the special leave petition was filed with an unexplained 358-day delay and the precedent relied upon had attained finality; consequently, the SLP was dismissed on delay as well as on merits.</description>
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