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    <title>2026 (6) TMI 1044 - ITAT PUNE</title>
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    <description>Contracts for sewage and water-treatment infrastructure were treated as development arrangements, not mere civil works, because the assessee undertook designing, engineering, procurement, construction, commissioning, operation and maintenance, and also bore financial and execution risks such as deposits, defect liability, liquidated damages and cost overruns. Applying the settled distinction between a developer and a works contractor, the Tribunal noted that government control over broad project parameters and receipt of periodic payments did not by itself make the assessee a contractor. On that factual matrix, the assessee was regarded as a developer and deduction under section 80IA(4) was allowable.</description>
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      <title>2026 (6) TMI 1044 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=793663</link>
      <description>Contracts for sewage and water-treatment infrastructure were treated as development arrangements, not mere civil works, because the assessee undertook designing, engineering, procurement, construction, commissioning, operation and maintenance, and also bore financial and execution risks such as deposits, defect liability, liquidated damages and cost overruns. Applying the settled distinction between a developer and a works contractor, the Tribunal noted that government control over broad project parameters and receipt of periodic payments did not by itself make the assessee a contractor. On that factual matrix, the assessee was regarded as a developer and deduction under section 80IA(4) was allowable.</description>
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