Read SC Judgment: SC Dismisses Tax Appeal as Developer Status Under Section 80IA Already SettledBoth parties submitted that the issue was no longer res integra, as an identical question had already been decided by the same Court in Tax Appeal No. The assessee had placed detailed material before the authorities to demonstrate its role as a developer. Concurrent factual findings were recorded by the Commissioner (Appeals) and the Tribunal that the assessee had undertaken development of infrastructure facilities. 80IA(4) of the Income Tax Act, 1961 by holding that the assessee is not a contractor but a developer of infrastructure facilities and is eligible for deduction u/s. Accordingly any person who executes the Infrastructure l’acility related work in capacity of a “Developer” shall only be allowed deduction u/s 801A(4) of the Act.