DCIT (OSD) v. Sanathnagar Enterprise Ltd. (2022) 196 ITD 89 (Mum.)(Trib.)

S. 36(1)(iii) : Interest on borrowed capital-Real estate construction-Method of accounting-Percentage completion method-Stock in trade-Work in progress-Allowable as deduction. [S. 145]

Assessee is engaged in business of real estate construction. It followed percentage completion method of accounting for revenue recognition and claimed interest cost incurred on its borrowings as deduction under section 36(1)(iii) of the Act.  Assessing Officer held  that expenses related to project were to be charged to cost of project and would be claimed as deduction when corresponding income of project was offered to tax  and    disallowed claim of assessee and added interest expense to work-in-progress. Held that  since funds borrowed by assessee were for project undertaken by it which constituted its stock-in-trade and not capital assets, interest expenditure incurred on said borrowed funds was to be allowed in year expenditure was incurred irrespective of fact that assessee followed percentage completion method for revenue recognistion.  (AY. 2013-14, 2014-15)