In the result, revenue’s appeal for A
Bench: Shri Rajpal Yadav Hon'Ble & Shri Manish Borad&
disallowed by the Ld. AO in the assessment order wherein he held that the assessee is merely executing government contract in the capacity of a work contractor and not developer. AO further observed that no risk is undertaken by the assessee and therefore, it cannot be termed as developer as envisaged u/s 80IA(4) of the Act. In the appellate