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    <title>2026 (8) TMI 691 - ITAT DELHI</title>
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    <description>Interest for failure to deduct tax on lease-rent payments is confined to the period from the date of deductibility until the deductee files its return. Disallowance for non-deduction of tax applies only to expenditure claimed as a revenue deduction in computing taxable income. Interest capitalised as inventory or work-in-progress under the percentage-of-completion method, and not charged to the profit and loss account, cannot be disallowed because it has not been claimed as deductible expenditure. Consequently, capitalised interest is excluded from the disallowance, while interest liability for non-deduction ends on the deductee&#039;s return-filing date.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796818</link>
      <description>Interest for failure to deduct tax on lease-rent payments is confined to the period from the date of deductibility until the deductee files its return. Disallowance for non-deduction of tax applies only to expenditure claimed as a revenue deduction in computing taxable income. Interest capitalised as inventory or work-in-progress under the percentage-of-completion method, and not charged to the profit and loss account, cannot be disallowed because it has not been claimed as deductible expenditure. Consequently, capitalised interest is excluded from the disallowance, while interest liability for non-deduction ends on the deductee&#039;s return-filing date.</description>
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