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    <title>Infrastructure deduction under section 80IA(4) allowed for consortium member treated as developer, not works contractor.</title>
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    <description>A constituent of joint ventures and consortiums formed to bid for government infrastructure contracts was treated as eligible for deduction under section 80IA(4) because the arrangements were pass-through vehicles, with execution, risk, and profit sharing resting on the members in their agreed proportions. The absence of a direct contract in the assessee&#039;s own name did not defeat eligibility where its participation was substantively through the consortium contract. The Tribunal also held that the Explanation to section 80IA(13) excludes only pure works contracts; the assessee, having undertaken design, procurement, construction, commissioning, and operation and maintenance obligations while bearing entrepreneurial and investment risk, was a developer and not a works contractor. Deduction was therefore allowed for both assessment years.</description>
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    <pubDate>Fri, 22 May 2026 07:06:44 +0530</pubDate>
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      <title>Infrastructure deduction under section 80IA(4) allowed for consortium member treated as developer, not works contractor.</title>
      <link>https://www.taxtmi.com/highlights?id=100019</link>
      <description>A constituent of joint ventures and consortiums formed to bid for government infrastructure contracts was treated as eligible for deduction under section 80IA(4) because the arrangements were pass-through vehicles, with execution, risk, and profit sharing resting on the members in their agreed proportions. The absence of a direct contract in the assessee&#039;s own name did not defeat eligibility where its participation was substantively through the consortium contract. The Tribunal also held that the Explanation to section 80IA(13) excludes only pure works contracts; the assessee, having undertaken design, procurement, construction, commissioning, and operation and maintenance obligations while bearing entrepreneurial and investment risk, was a developer and not a works contractor. Deduction was therefore allowed for both assessment years.</description>
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      <pubDate>Fri, 22 May 2026 07:06:44 +0530</pubDate>
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