ACIT., CIRCLE-8(1), HYDERABAD vs. NCC HES JV, HYDERABAD

In the result, all the appeals of the Revenue are dismissed

801A of\nthe I.T. Act.\nThe assessee, therefore, prays the Hon'ble ITAT to kindly dismiss the\nappeals filed by the Revenue.\nWe have heard the rival submissions and perused the\nmaterial on record. In the present case, the sole objection of the\nAO is that the infrastructure facility created by the assessee\nthe formation of ‘Venkatadri Reservoir Bund' – does

CELESTIAL AVENUES PVT LTD REP. BY CSK PROPERTIES PVT LTD ON MERGER-PAN-AADCC3990R,HYDERABAD. vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE -1(2), HYDERABAD.

In the result, all the appeals of the assessee are allowed

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha G, Hon’Bleआ.अपी.सं / Ita Nos.212 To 214/Hyd/2019 (निर्धारण वर्ा / Assessment Years: 2006-07, 2007-08 & 2008-09) M/S. Sabir, Sew & The Deputy Commissioner Of Prasad, Jv, Vs. Income Tax, Hyderabad. Circle – 6(1), Hyderabad. Pan : Abcfs2425A अपीलार्थी / Appellant प्रत्‍यर्थी / Respondent

801A(4) of the Act. Thus, the grounds of appeal filed by the assessee are dismissed.” 6. Feeling aggrieved with the order of LD.CIT(A), the assessee is now in appeal before us. 6.1. First, we will deal with the additional grounds raised by the assessee. 7. Before us, the ld.AR submitted that the assessment order was passed

SABIR , SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

801A.\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

SABIR, SEW 7 PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

801A.\n\n23.2 From the above reading, it is clear that prior to the insertion\nof the Finance Act, 2007, there was no such Explanation, and it\nwas only by way of the Explanation that a specific category of\npersons executing works contracts was excluded from Section\n80IA of the Act. This exclusion applied only to works contracts'\nawarded

SABIR, SEW & PRASAD JV,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX , CIRCLE-6(1), HYDERABAD

In the result, all the appeals of the assessee are allowed

801A(4) of the Act.\n\n7.9 At this juncture, it is important to note that there is a clear difference\nand distinction between the terms \"developer\" and \"contractor\". Further,\nnormally, any \"works contract\" awarded by the Government to a\ncontractor by way of a tender process would fall under the ambit of the\ncontractor rather than developer. This issue

SANGHI INDUSTRIES LIMITED,HYDERABAD vs. DCIT, CIRCLE -3 (1), HYDERABAD

In the result, the appeal of the assessee is dismissed

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

801A. The eligible business is defined in section 80IA(1) with reference to the section 80IA(4). Nowhere in any of these sub-sections, does eligible business mean business claiming the deduction u/s 80IA. Therefore, the argument that assessee is not claiming any deduction in the year concerned is of no relevance. (b)Whether or not the 80IA deduction