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Assessee has raised the ground that the learned Commissioner of Income-tax (Appeal)-1, Rajkot [hereinafter referred to as the CIT(A)] erred on facts as also in law in confirming the disallowances of claim of deduction u/s.80IA(4) of the Income-tax Act.1961 [hereinafter referred as to the "Act"] off Rs. 1,95,05,203/- made by the Assessing Officer on the alleged ground that the appellant is not eligible for deduction u/s.80IA(4) as the appellant is executing a works contract.

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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 - [2020] 27 ITCD Online 067 (ITAT-RAJKOT)