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    <title>2025 (7) TMI 2047 - GUJARAT HIGH COURT</title>
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    <description>Deduction under Section 80IA(4) was upheld where the assessee was found on concurrent facts to be a developer of infrastructure facilities and not a mere works contractor; the explanation below Section 80IA(13) was treated as excluding only works contracts, so the claim succeeded. Revenue expenditure for the Singhara project was also allowed under Section 37 because the business had already commenced, the outlay was incurred in ongoing operations, and it was not capital in nature. Deduction under Section 35AD could not be denied merely because the contract was initially routed through a joint venture, since the assessee actually executed the project and offered the income to tax. The Revenue&#039;s challenge failed on all issues.</description>
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      <title>2025 (7) TMI 2047 - GUJARAT HIGH COURT</title>
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      <description>Deduction under Section 80IA(4) was upheld where the assessee was found on concurrent facts to be a developer of infrastructure facilities and not a mere works contractor; the explanation below Section 80IA(13) was treated as excluding only works contracts, so the claim succeeded. Revenue expenditure for the Singhara project was also allowed under Section 37 because the business had already commenced, the outlay was incurred in ongoing operations, and it was not capital in nature. Deduction under Section 35AD could not be denied merely because the contract was initially routed through a joint venture, since the assessee actually executed the project and offered the income to tax. The Revenue&#039;s challenge failed on all issues.</description>
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