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2025 Supreme(Online)(ITAT) 2791

INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
LALIET KUMAR, J
Joint Venture (JV) – Appellant
Versus
Commissioner of Income Tax (Appeals) – 6, Hyderabad – Respondent


Advocates:
For the Appellants/Petitioners: Shri A. Srinivas, C.A.
For the Respondents: Shri Srinath Sadanala, Sr.DR

Table of Content
1. identifying the factual background of the case. (Para 1 , 4 , 5)
2. articulating the parties’ arguments regarding eligibility for deduction under section 80ia. (Para 2 , 3 , 6 , 7 , 8 , 9 , 10 , 11)
3. court's analysis on the necessity of direct agreement with the government for claiming deductions. (Para 12 , 13 , 16)
4. establishing criteria for developer status versus contractor status under section 80ia. (Para 14 , 15 , 17)
5. confirmation of the assessment outcomes and entitlements based on prior legal precedents. (Para 22 , 24 , 25 , 28)

ORDER

PER LALIET KUMAR, J.M :

These appeals filed by the assessee are directed against the separate orders of Commissioner of Income Tax (Appeals) – 6, Hyderabad dated 19.11.2018 for A.Y. 2006-07 20 2008-09. Since facts are identical and issues are common, for the sake of convenience, all the appeals filed by the assessee are being disposed of, by this consolidated order, by taking ITA No.212/Hyd/2019 for A.Y. 2006-07 as lead appeal.

2. The grounds of appeal filed by the assessee in ITA No.212/Hyd/2019 read as under :

“1. The order of the Appellate Commissioner is contrary to law, facts and circumstances of the case.

2. The Appel

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