Shanti Prime Publication Pvt. Ltd.
Sec. 80IA(4) of Income Tax Act, 1961— Deduction — Even after the amendment by the Finance Act, 2007 and the Finance Act, 2009, the contractors performing the work in the nature of a developer-cum-contractor and assuming risks and responsibilities shall be eligible for deduction under section 80-IA in respect of the eligible infrastructural facilities - The cardinal rule for interpretation of any provision relating to exemption, allowance, deduction, rebate or relief is that they should be interpreted liberally and broadly so as to advance the object sought to be achieved and not frustrate it, thus, even on this count, it can be said that the contractors performing function of a developer shall be given benefit of deduction under section 80-IA (4) - PATEL INFRASTRUCTURE PVT. LTD. V/s DEPUTY CIT -  27 ITCD Online 067 (ITAT-RAJKOT)