Following questions of law is admitted which is to be heard along with ITA Nos . 183 of 2012 and 184 of 2012 .

(a) Whether , the respondent / assessee fulfils  the requirement stipulated in section 80IA(4) of the Income tax Act 1961 once the conclusion reached is that it is contractor and not developer as stated in the sub-section ?

(b) Whether , in the facts and circumstances of the case the Income Tax Appellate Tribunal was right in holding that even if the assessee is termed as contractor he had developed , operated and maintained  infrastructural facility and hence entitle to the deductions with in the meaning of sub- section ?    (ITA No . 1769 of 2016 dt 30 -01 2019)