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“infrastructure facility”

DeductionsSection 80IA(4)Section 80IA(4)531 judgments

The decision most relied on for infrastructure facility is CIT v. ABG Heavy Industries Ltd. (322 ITR 323), cited in 229 judgments on BharatTax.

Leading authorities on infrastructure facility

CIT v. ABG Heavy Industries Ltd.
322 ITR 323 · 2010 · High Court
229
citing judgments

The Assessing Officer cannot deny a Section 80IA deduction by merely asserting that the assessee is not a "developer" without considering the relevant agreements and facts. Entitlement to Section 80IA deduction requires a thorough examination of the assessee's role as a developer.

M/s. GVPR Engineers Ltd. v. ACIT
51 SOT 207 · 2012 · ITAT
89
citing judgments

Deduction under section 80-IA is available to developers who undertake entrepreneurial investment risk, not merely to contractors who undertake business risk. The nature of the work undertaken determines eligibility.

T.M.A. Pai Foundation v. State of Karnataka
8 SCC 481 · 2002 · Reported
81
citing judgments

Educational institutions are not commercial activities, and collecting fees for betterment and growth does not automatically disqualify them from being considered educational. Fees collected for value-added courses, training, or hostel facilities can be eligible for exemption under Section 11 if applied towards the institution's infrastructure.

Katira Construction Ltd. v. UOI
31 Taxmann.com 250 · 2013 · High Court
77
citing judgments

A person entering into a works contract with an enterprise eligible for deduction under Section 80-IA is not entitled to claim the tax benefit under Section 80-IA of the Act.

Katira Constructions Limited v. Union of India and Others
352 ITR 513 · 2013 · High Court
70
citing judgments

The Gujarat High Court holds that the explanation to Section 80-IA(4) of the Income-tax Act, regarding works contracts for infrastructure facilities, is clarificatory and explanatory in nature, not an amendment with retrospective effect. Its vires are upheld as it does not levy tax retrospectively.

CIT v. Glenmark Pharmaceuticals Ltd.
324 ITR 199 · 2010 · High Court
69
citing judgments

A taxpayer is eligible for deduction under Section 80IA for developing and operating infrastructure facilities, with the decision clarifying the distinction between a contractor and a developer for this purpose.

Asstt. CIT v. Pratibha Industries Ltd.
141 ITD 151 · 2013 · ITAT
64
citing judgments

Where an assessee invests its own funds in an infrastructure development project, it is presumed to be acting as a developer, not merely a contractor, making it eligible for deduction under section 80-IA(4).

B.T. Patil& Sons Belgaum Construction P. Ltd. v. ACIT
126 TTJ 577 · 2009 · ITAT
63
citing judgments

A Special Bench decision of the Income Tax Appellate Tribunal concerning Section 80IA deduction for infrastructure facility developers can be recalled if it fails to consider a binding jurisdictional High Court judgment.

Judgments citing infrastructure facility

Deputy Commissioner of Income Tax, Nariman Point, Mumbai vs. Beil Infrastructure Limited, Gujarat

In the result, both the appeals of the revenue are dismissed

ITA 2732/MUM/2023[2017-18]Status: DisposedITAT Mumbai04 Jun 2024AY 2017-18

Bench: Justice (Retd.) C V Bhadang, Hon’Ble& Shri B.R. Baskaranassessment Year 2017-18 Assessment Year 2018-19

For Appellant: Shri S.Srinivasu, CIT-DR &For Respondent: Shri Kirit Kamdar &
Section 80I

Assessment Year 2017-18 Assessment Year 2018-19 activities were executed through separate undertakings, viz., Land Fill and Incinerators. They are considered as “infrastructure facilities’ eligible for deduction u/s 80IA(4) of the Act. Each of the Land fill and Incinerator is considered as separate undertaking for the purpose ... land fill project No.1 in AY 2002-03 that is in the initial year, therefore, deduction under section 80-IA in respect of the infrastructure facility should have been allowed to the assessee. So far as the objection of the Ld. Sr. DR for the revenue is concerned that

Deputy Commissioner of Income Tax, Central Circle 6(3), Mumbai vs. Beil Infrastructure Limited, Gujarat

In the result, both the appeals of the revenue are dismissed

ITA 2729/MUM/2023[2018-19]Status: DisposedITAT Mumbai04 Jun 2024AY 2018-19

Bench: Justice (Retd.) C V Bhadang, Hon’Ble& Shri B.R. Baskaranassessment Year 2017-18 Assessment Year 2018-19

For Appellant: Shri S.Srinivasu, CIT-DR &For Respondent: Shri Kirit Kamdar &
Section 80I

Assessment Year 2017-18 Assessment Year 2018-19 activities were executed through separate undertakings, viz., Land Fill and Incinerators. They are considered as “infrastructure facilities’ eligible for deduction u/s 80IA(4) of the Act. Each of the Land fill and Incinerator is considered as separate undertaking for the purpose ... land fill project No.1 in AY 2002-03 that is in the initial year, therefore, deduction under section 80-IA in respect of the infrastructure facility should have been allowed to the assessee. So far as the objection of the Ld. Sr. DR for the revenue is concerned that

ACIT, Cir 8(2)(1), Mumbai vs. Star Track Terminals Pvt. Ltd., Greater Noida

In the result, both the appeals of the revenue are dismissed

ITA 4394/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 May 2024AY 2017-18

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeassessment Year :2016-17 Assessment Year : 2017-18

For Appellant: Shri Manish KantFor Respondent: Ms. Sujatha Iyangar, Sr.AR
Section 263Section 80Section 80I

Court. The Assessing Officer however, placed reliance on a Circular issued by CBDT, wherein it was opined that the inland port does not constitute infrastructure facility for the purposes of sec. 80IA of the Act. The assessee further pointed out that similar claim made by it in the earlier years

ACIT, Cir 8(2)(1), Mumbai vs. Star Track Terminals Pvt. Ltd., Greater Noida

In the result, both the appeals of the revenue are dismissed

ITA 4393/MUM/2023[2016-17]Status: DisposedITAT Mumbai22 May 2024AY 2016-17

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeeassessment Year :2016-17 Assessment Year : 2017-18

For Appellant: Shri Manish KantFor Respondent: Ms. Sujatha Iyangar, Sr.AR
Section 263Section 80Section 80I

Court. The Assessing Officer however, placed reliance on a Circular issued by CBDT, wherein it was opined that the inland port does not constitute infrastructure facility for the purposes of sec. 80IA of the Act. The assessee further pointed out that similar claim made by it in the earlier years

DCIT, Circle, Hisar vs. Gawar-Ciegall (J.V.), Hisar

ITA 1404/DEL/2023[2017-18]Status: DisposedITAT Delhi17 May 2024AY 2017-18

Bench: Sh. Kul Bharatdr. B. R. R. Kumar

For Appellant: Sh. Ashwani Kumar, CA &For Respondent: Sh. Vivek Kr. Upadhyay, Sr. DR
Section 133(6)Section 68Section 801A(4)

provisions of section 801A(4) only such enterprise which is owned by an Indian Company or Consortium of Indian companies carrying/engaged in infrastructure facility are eligible for deduction under this section. In the instant case, assessee is a partnership firm bearing two Indian companies as partners having

DCIT, Circle-2(1)(2), Ahmedabad vs. Kota Baran Tollway Pvt. Ltd, Ahmedabad

In the result, the appeal of the Department is dismissed

ITA 2025/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Apr 2024AY 2014-15

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokar

For Appellant: Shri Sudhendu Das, CIT-DRFor Respondent: Shri Jaimin Shah, A.R
Section 80I

facts in allowing the deduction u/s 80IA(4) since the assessee is neither a developer nor is operating and maintaining any infrastructural facility which is the eligibility condition for availing the deduction u/s 80IA(4) of the Act. 1.1 The Ld CIT(A) has erred in law and on facts ... appeal is hereby being condoned. On Merits: 6. The brief facts of the case are that the assessee is engaged in business of building infrastructure facilities and earning income by way of collecting toll from vehicles running on roads constructed by the assessee. DCIT vs. Kota Baran Tollway

The Dy. CIT, Patan Circle, Patan vs. Ajay Engineering Infrastructure Pvt. Ltd., Unjha

In the result appeal of the Revenue in ITA no

ITA 1621/AHD/2017[2014-15]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2014-15

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

profit and gains derived from the enterprises which should be (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility. The assessee has entered into contract agreements as a ‘Contractor’ and earned income as ‘Contract receipts’ which income is not entitled for deduction under ... eligible for deduction under section 80IA(4) because the income should be derived from the enterprise/ undertaking developing, operating and maintaining of the infrastructure facilities. The AO observed that the first condition of Section 80IA(4) is that the enterprise should be owned by a Company. The AO also observed

The Dy.Commissioner of Income Tax, Patan Circle, Patan vs. Ajay Engg. Infrastructure Pvt. Ltd., Unjha

In the result appeal of the Revenue in ITA no

ITA 1231/AHD/2016[2013-14]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2013-14

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

profit and gains derived from the enterprises which should be (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility. The assessee has entered into contract agreements as a ‘Contractor’ and earned income as ‘Contract receipts’ which income is not entitled for deduction under ... eligible for deduction under section 80IA(4) because the income should be derived from the enterprise/ undertaking developing, operating and maintaining of the infrastructure facilities. The AO observed that the first condition of Section 80IA(4) is that the enterprise should be owned by a Company. The AO also observed

The Dy. CIT, Patan Circle, Patan vs. Ajay Engineering Infrastructure Pvt. Ltd., Unjha

In the result appeal of the Revenue in ITA no

ITA 2303/AHD/2014[2011-12]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2011-12

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

profit and gains derived from the enterprises which should be (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility. The assessee has entered into contract agreements as a ‘Contractor’ and earned income as ‘Contract receipts’ which income is not entitled for deduction under ... eligible for deduction under section 80IA(4) because the income should be derived from the enterprise/ undertaking developing, operating and maintaining of the infrastructure facilities. The AO observed that the first condition of Section 80IA(4) is that the enterprise should be owned by a Company. The AO also observed

The Dy. CIT, Patan Circle, Patan vs. Ajay Engineering Infrastructure Pvt. Ltd., Unjha

In the result appeal of the Revenue in ITA no

ITA 2302/AHD/2014[2010-11]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2010-11

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

profit and gains derived from the enterprises which should be (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility. The assessee has entered into contract agreements as a ‘Contractor’ and earned income as ‘Contract receipts’ which income is not entitled for deduction under ... eligible for deduction under section 80IA(4) because the income should be derived from the enterprise/ undertaking developing, operating and maintaining of the infrastructure facilities. The AO observed that the first condition of Section 80IA(4) is that the enterprise should be owned by a Company. The AO also observed

The ACIT, Patan Circle, Patan vs. Ajay Engineering Infrastructure Pvt. Ltd., Unjha

In the result appeal of the Revenue in ITA no

ITA 2118/AHD/2013[2009-10]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2009-10

Bench: Shri Ramit Kochar & Ms. Madhumita Royassessment Year: 2009-10 Assessment Year:2010-11 Assessment Year: 2011-12 Assessment Year: 2013-14 Ita Nos. 1621/Ahd/2017 Assessment Year: 2014-15 The Acit, Patan Circle, Room No.104, Ajay Engineering Infrastructure 1St Floor, Santokba Hall, Rajmahal V. Pvt. Ltd., 98, Old Market Yard, Road, Patan-384265, Gujarat Unjha-384170 Gujarat Pan:Aagca8877L (Appellant) (Respondent) Assessment Year: 2014-15 The Dcit, Patan Circle, Room M/S Ajay Protech Pvt. Ltd., 59, No.101/4, 1St Floor, Chinmay V. Pratap Chambers 1St Floor, Near Corporate House, Patan-Deesa Railway Circle, Unjha-384170, Highway, Patan-384265,Gujarat Gujarat Pan:Aajca4095R (Appellant) (Respondent) Assessee By: Sh. S.N. Soparkar, Sr. Advocate & Sh. Parin Shah, A.R. Revenue By: Sh. Chetram Meena, Sr. Dr Date Of Hearing: 24.01.2024 Date Of Pronouncement: 19.04.2024

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

profit and gains derived from the enterprises which should be (i) developing or (ii) operating and maintaining or (iii) developing, operating and maintaining any infrastructure facility. The assessee has entered into contract agreements as a ‘Contractor’ and earned income as ‘Contract receipts’ which income is not entitled for deduction under ... eligible for deduction under section 80IA(4) because the income should be derived from the enterprise/ undertaking developing, operating and maintaining of the infrastructure facilities. The AO observed that the first condition of Section 80IA(4) is that the enterprise should be owned by a Company. The AO also observed

Khurana Engineering Ltd., Ahmedabad vs. The ACIT.(OSD), Circle-1, Ahmedabad

ITA 2357/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2008-09

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

assessee is in the nature of contractor. The assessee submitted before the AO that the consideration is paid by respective government authorities for executing infrastructure facility as a developer and not as a contractor. The assessee submitted before the AO that it has to undertake extensive liability which lasts till ... with the various govt. authorities. The assessee company has not deriving income from developing or operating and maintaining or developing, operating and maintaining any infrastructure facility and the assessee company has earned income as contract receipt and this income being a contract receipt is not eligible for 80IA(4) deduction

The ACIT.(OSD), Circle-1, Ahmedabad vs. Khurana Engineering Ltd., Ahmedabad

ITA 2352/AHD/2011[2008-09]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2008-09

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

assessee is in the nature of contractor. The assessee submitted before the AO that the consideration is paid by respective government authorities for executing infrastructure facility as a developer and not as a contractor. The assessee submitted before the AO that it has to undertake extensive liability which lasts till ... with the various govt. authorities. The assessee company has not deriving income from developing or operating and maintaining or developing, operating and maintaining any infrastructure facility and the assessee company has earned income as contract receipt and this income being a contract receipt is not eligible for 80IA(4) deduction

The ACIT.(OSD), Circle-1, Ahmedabad vs. Khurana Engineering Ltd., Ahmedabad

ITA 2308/AHD/2011[2007-08]Status: DisposedITAT Ahmedabad19 Apr 2024AY 2007-08

Bench: Shri Ramit Kochar & Ms. Madhumita Roya.Y. 2007-08

For Appellant: Sh. S.N. Soparkar, Sr. Advocate & Sh. ParinFor Respondent: Sh. Chetram Meena, Sr. DR
Section 143(2)Section 143(3)Section 80I

assessee is in the nature of contractor. The assessee submitted before the AO that the consideration is paid by respective government authorities for executing infrastructure facility as a developer and not as a contractor. The assessee submitted before the AO that it has to undertake extensive liability which lasts till ... with the various govt. authorities. The assessee company has not deriving income from developing or operating and maintaining or developing, operating and maintaining any infrastructure facility and the assessee company has earned income as contract receipt and this income being a contract receipt is not eligible for 80IA(4) deduction

ACIT Circle 1(2)(1), Mumbai vs. M B Patil Construction Limited, Mumbai

ITA 98/MUM/2023[2018-19]Status: DisposedITAT Mumbai16 Apr 2024AY 2018-19
Section 143(3)Section 145(3)Section 40Section 44A

there is no reference to the term "road widening" anywhere in Work Order and has not carried out any work of development of new infrastructure facility or maintaining the same"? 4. "On the facts and in the circumstance of the case and in law the ld. CIT (Appeals) failed ... completion of the contractual obligations has been paid the agreed contract price as per work completed whereas section 801A stipulates development or maintenance of Infrastructure facility"? 5. "On the facts and in the circumstance of the case and in law the ld. CIT Appeals) failed to appreciate the fact that

M/S M.B.Patil Constructions Limited, Mumbai vs. Income Tax Department, National Faceless Assessment Centre, Delhi

ITA 303/MUM/2023[2018-19]Status: DisposedITAT Mumbai16 Apr 2024AY 2018-19
Section 143(3)Section 145(3)Section 40Section 44A

there is no reference to the term "road widening" anywhere in Work Order and has not carried out any work of development of new infrastructure facility or maintaining the same"? 4. "On the facts and in the circumstance of the case and in law the ld. CIT (Appeals) failed ... Nos.303 & 98/Mum/2023 M/s. Patil Construction and Infrastructure Limited (M.B. Patil Constructions Limited since amalgamated) whereas section 801A stipulates development or maintenance of Infrastructure facility"? 5. "On the facts and in the circumstance of the case and in law the ld. CIT Appeals) failed to appreciate the fact that the relationship

Itd Cementation India Ltd, Mumbai vs. DCIT CC-5(1), Mumbai

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 1401/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 Feb 2024AY 2018-19

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am Dcit Itd Cementation India Ltd. Central Circle 5(1) 9Th Floor, Prima Bay, Room No.1928, 19 Th Floor, Tower-B, Gate No.5, Air India Building, Vs. Saki Vihar Road, Powai, Nariman Point, Mumbai-400 072 Mumbai-400 021 (Appellant) (Respondent) Pan No. Aaact1426A Assessee By : Shri Vijay Mehta, Ar Revenue By : Shri Ramkrishna Bandi, Cit Dr Date Of Hearing: 18.12.2023 Date Of Pronouncement : 22.02.2024

For Appellant: Shri Vijay Mehta, ARFor Respondent: Shri Ramkrishna Bandi, CIT DR
Section 115Section 115JSection 143(3)Section 144BSection 14ASection 36(1)(va)Section 80Section 80I

respect of the contracts awarded by Government or local or statutory authorities for developing and/or operating and/or maintaining a new infrastructure facility. 3. The Hon'ble CIT(A)-53 has erred in confirming the action of the Ld. AO in disallowing Rs. 1,97,740 under Section ... various projects and found that such contracts were awarded by private parties. He also examined that whether the assessee is operating or maintaining any infrastructure facilities or not with respect to certain contracts. He found that assessee is ITD Cementation India Ltd; A.Y. 2018-19 entitled for deduction for part

Shree Cement Limited, Beawar vs. National Faceless Assessment Centre, Delhi

In the result, the appeal of the Revenue in ITA No

ITA 500/JPR/2023[215-16]Status: DisposedITAT Jaipur21 Feb 2024

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

confirmed. The ground of appeal is dismissed.” 4.6 Ground no. 19 before the ld. CIT(A) was that deduction on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision is also available while computing book profit u/s. 115JB which was not considered ... Book Profit under section 115JB of the Act. 22. Brief facts of this case that the assessee has claimed deduction u/s. 80IA on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision of the Act. The assessee contended that said claim

Shree Cement Limited, Beawar vs. National Faceless Assessment Assessment Centre, Deputy Commissioner of Income Tax, Circle-2, Ajmer

ITA 497/JPR/2023[2017-18]Status: DisposedITAT Jaipur21 Feb 2024AY 2017-18
Section 115JSection 143Section 143(3)Section 144B(1)(xvi)Section 80Section 80I

confirmed. The ground of appeal is dismissed.” 4.6 Ground no. 19 before the ld. CIT(A) was that deduction on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision is also available while computing book profit u/s. 115JB which was not considered ... Book Profit under section 115JB of the Act. 22. Brief facts of this case that the assessee has claimed deduction u/s. 80IA on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision of the Act. The assessee contended that said claim

Shree Cement Limited, Beawar vs. National Faceless Assessment Centre, Deputy Commissionerof Income Tax, Circle -2, Ajmer

In the result, the appeal of the Revenue in ITA No

ITA 496/JPR/2023[2016-17]Status: DisposedITAT Jaipur21 Feb 2024AY 2016-17

Bench: or at the time of hearing of this appeal.

For Appellant: Sh. Dilip B Desai(C.A.)For Respondent: Sh. Alka Gautam (CIT) (V.H) &
Section 115JSection 143Section 143(3)Section 144BSection 144B(1)(xvi)Section 80Section 80I

confirmed. The ground of appeal is dismissed.” 4.6 Ground no. 19 before the ld. CIT(A) was that deduction on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision is also available while computing book profit u/s. 115JB which was not considered ... Book Profit under section 115JB of the Act. 22. Brief facts of this case that the assessee has claimed deduction u/s. 80IA on various infrastructure facilities and power undertakings amounting to Rs. 7,13,42,76,504/- under regular provision of the Act. The assessee contended that said claim