The AO disallowed conversion/development expenses treating them as capital expenditure. The assessee argued the amount was debited in P&L and was included in closing stock under Land & Building Stock-in-Trade. Therefore, there was no reduction of taxable income. On appeal, ITAT observed that the said treatment was tax neutral as the amount was already reflected in closing stock. Mere nomenclature like ‘Capital WIP’ does not determine tax treatment. The ITAT accepted this explanation and held that no addition was justified (AY. 2014-15, 2015-16, 2017-18)