Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreements.

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....Section 80-IA(4) deduction for infrastructure development may be available to an EPC enterprise executing Government water, sewage and industrial-effluent projects where it substantively develops eligible infrastructure and satisfies statutory conditions. A contractual description as a works contractor does not, by itself, bar eligibility. Consistency with an earlier decision on substantially similar facts applies where no material factual or legal change, or contrary higher-forum ruling, is shown. On these principles, the deduction was sustained and the Revenue's challenge failed.....