Interest Deduction Dispute u/s 36(1) of Income Tax Act: Capital vs. Revenue Classification Debate.

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....Deduction of Interest u/s 36(1) - Capital OR revenue - Assessee has also not claimed before us or before the Authorities below that the land in question was put to use in the Assessment Years in question - The words in the Proviso to Section 36(1) "whether capitalised or not" will override the provisions contained in Section 145A/accounting practice followed in the Books - not allowable....