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    <title>2026 (1) TMI 1111 - ITAT DELHI</title>
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    <description>Assessees adoption of the percentage completion method and ICAI guidance meant revenue was not recognised until threshold met; accordingly advertising, promotion and commission expenses were allowable as business expenditure and CIT(A) decision restored. Interest on debentures and funds raised to finance project were held to require capitalisation as project cost, leading to disallowance by AO and direction to capitalise. Debenture issue expenditure treated as loan-related and allowed in part. Notional interest on interest-free advances to a related concern was to be recalculated using assessees cost of capital, partly sustaining revenues claim. TDS on non-resident interest was found excessly deposited, so AOs reverse-calculation disallowance was deleted.</description>
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