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    <title>2024 (9) TMI 1951 - ITAT AHMEDABAD</title>
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    <description>Infrastructure developers claiming section 80IA(4) relief are treated as eligible where they bear project risk, arrange resources, and execute the work as a developer rather than a mere works contractor, and the rule of consistency supported the claim. Revenue expenditure incurred after project allotment and before the appointed date was allowed because it was genuine, commercially expedient, and not capital in nature. Deduction under section 35AD was not denied merely because a project was initially awarded to a joint venture that acted only as a bidding vehicle. The note also records that consequential disallowance under section 40(a)(ia) and the recalculated enhanced deduction were upheld on the facts.</description>
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