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The assessee is supplying heavy earthmoving machinery on hiring basis to GMDC.Accordingly, the learned CIT (A) held that there cannot be any deduction with respect to such projects under section 80-IA(4) of the Act, as the assessee is not executing any projects eligible for deduction specified under section 80-IA(4) of the Act.

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Sec. 80IA(4),153A of Income Tax Act, 1961 - Assessment - The assessee is in development of the infrastructure facilities eligible for deduction under section 80 IA(4) of the Act.—KETAN CONST RUCTION LTD. vs. DEPUTY CIT.[2020] 26 ITCD Online 016 (ITAT-RAJKOT)