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    <title>2024 (12) TMI 1788 - ITAT DELHI</title>
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    <description>Milestone-based financial assistance received during development of water-supply infrastructure under a BOT concession is capital in character where it is linked to construction milestones and intended to establish or complete the project. Applying the purpose test, the assistance is not taxable as revenue and reduces capital work-in-progress. Capital work-in-progress expenditure supported by sub-contractor invoices cannot be disallowed on an ad hoc basis merely because every item cannot be verified. An estimated disallowance requires identified defects or evidence that expenditure is inflated, excessive, or non-genuine. Both additions were deleted.</description>
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