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2018 (1) TMI 579 - AT - Income TaxAddition u/s 36(1)(iii) for non-capitalisation of interest on advance given for land purchased and for non-capitalisation of interest on opening capital work-in-progress - sufficient interest-free funds for advancing for purchase for land and also for construction - Held that:- As far as the legal and factual position as considered by the Commissioner of Income-tax (Appeals), we find there is no infirmity pointed out by the Revenue on record. The fact that to the extent relief has been granted, the conclusion has been drawn on the basis of facts that the purchase and construction was from the interest-free funds available to the assessee which finding of fact we note remains unassailed on record. Arguments to the contrary advanced by the learned senior Departmental representative are found to be exfacie contrary to facts on record. The facts on record that entire interest expenditure on term loan from Allahabad Bank has duly been capitalised is an accepted fact which remains unassailed and has constantly been argued even before the Assessing Officer - Decided against revenue
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