CIT v. Lokhandwala Construction Inds. Ltd.

Macrotech Developers Ltd.(Successor to Lodha Impression Real Estate P. Ltd.), Mumbai vs. Dy CIT Central Range-7(3), Mumbai

In the result, appeal by the assessee is allowed

Bench: Shri G. S. Pannu & Shri Vikas Awasthyआअसं. 527/मुं/2021 (िन.व. 2016-17) Macrotech Developers Ltd. (Successor To Lodha Impression Real Estate Private Limited,) 412, Floor -4, 17G Vardhaman Chamber, Cawasji Patel Road,Horniman Circle. Fort, Mumbai – 400 001 Pan: Aaacl-1490-J ...... अपीलाथ" /Appellant बनाम Vs. Dcit, Central Range – 7(3), Room No.655, 6Th Floor, Aaykar Bhavan, M.K.Road, Mumbai 400 020. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Neeraj Seth "ितवादी "ारा/Respondent By : Dr. Mahesh Akhade सुनवाई की ितिथ/ Date Of Hearing : 11/08/2022 घोषणा की ितिथ/ Date Of Pronouncement : 09/11/2022 आदेश/ Order

…Similar issue was dealt with by the Co-ordinate Bench in the case of DCIT vs. Palava Dwellers Pvt. Ltd. (supra). The Tribunal following the decision rendered by Hon'ble Jurisdictional High Court in the case of CIT vs. Lokhandwala Construction Industries Ltd., 260 ITR 579 and various other decisions of the Tribunal concluded as under:- “7. On a careful perusal of the order of Ld.CIT(A), we do not see any infirmity in allowing the claim of the assessee as the claim of the assessee is in tune with the decision of the Hon'ble Jurisdictional High Court in the case of Lokandwala Construction (supra) wherein it has bee…

Asstt Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd .(Successor to M/S Sahajanad Hi-Tech Construction Pvt Ltd.), Mumbai

In the result, for A.Y. 2015-16, the appeal of the learned

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Macrotech Developers Ltd. (Successor To M/S Sahajanad Acit Cc-7(3) Hi-Tech Construction Pvt. Room No. 655, Ltd.) Aayakar Bhavan, 412,4Th Floor, 17-G, Vs. M.K.Road, Vardhaman Chambers, Mumbai- 400 020 Cawasji Patel Road, Horniman Cirlce, Fort, Mumbai-400001 (Respondent) (Appellant) Pan No.Aaecp1936F Acit Cc-7(3) Macrotech Developers Ltd. Room No. 655, (Successor To Bellissimo Aayakar Bhavan, Developers Thane Private Limited) M.K.Road, 412, Floor-4, 17G Vs. Mumbai- 400 020 Vardhman Chamber, Cawasji, Patel Road, Horniman Circle, Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D ‘Ita No. 1864/Mum/2022 (Assessment Year 2015-16) Macrotech Developers Ltd. Dcit, (Successor To Bellissimo Central Circle 7(3) Developers Thane Private Room No. 655, 6 Th Floor, Limited) 412, Floor-4, 17G Aaykar Bhavan, Vs. Vardhman Chamber, Cawasji, M. K. Road, Patel Road, Horniman Circle, Mumbai-400 021 Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D

…as deduction in the return of income in the year of incurring those expenses, interest is periodic cost and therefore, same is claimed as deduction. Assessee relied upon the decision of Hon'ble Bombay High Court in CIT vs. Lokhandwala Construction Inds. Ltd. 260 ITR 579 (Bom). 06. The learned Assessing Officer rejected the contention of the assessee. He held that as per Accounting Standard (AS)-7 and Guidance Note on Accounting for Real Estate Transactions issued by the Institute of Chartered Accountants of India, all the expenses directly related to the project must be carried over as the cost of the project. I…

Assistant Commissioner of Income Tax, Central Circle-7(3), Mumbai vs. M/S Macrotech Developers Ltd, Mumbai

In the result, for A.Y. 2015-16, the appeal of the learned

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Macrotech Developers Ltd. (Successor To M/S Sahajanad Acit Cc-7(3) Hi-Tech Construction Pvt. Room No. 655, Ltd.) Aayakar Bhavan, 412,4Th Floor, 17-G, Vs. M.K.Road, Vardhaman Chambers, Mumbai- 400 020 Cawasji Patel Road, Horniman Cirlce, Fort, Mumbai-400001 (Respondent) (Appellant) Pan No.Aaecp1936F Acit Cc-7(3) Macrotech Developers Ltd. Room No. 655, (Successor To Bellissimo Aayakar Bhavan, Developers Thane Private Limited) M.K.Road, 412, Floor-4, 17G Vs. Mumbai- 400 020 Vardhman Chamber, Cawasji, Patel Road, Horniman Circle, Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D ‘Ita No. 1864/Mum/2022 (Assessment Year 2015-16) Macrotech Developers Ltd. Dcit, (Successor To Bellissimo Central Circle 7(3) Developers Thane Private Room No. 655, 6 Th Floor, Limited) 412, Floor-4, 17G Aaykar Bhavan, Vs. Vardhman Chamber, Cawasji, M. K. Road, Patel Road, Horniman Circle, Mumbai-400 021 Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D

…as deduction in the return of income in the year of incurring those expenses, interest is periodic cost and therefore, same is claimed as deduction. Assessee relied upon the decision of Hon'ble Bombay High Court in CIT vs. Lokhandwala Construction Inds. Ltd. 260 ITR 579 (Bom). 06. The learned Assessing Officer rejected the contention of the assessee. He held that as per Accounting Standard (AS)-7 and Guidance Note on Accounting for Real Estate Transactions issued by the Institute of Chartered Accountants of India, all the expenses directly related to the project must be carried over as the cost of the project. I…

Macrotech Developers Ltd(Successor to Bellissimo Developers Thane Private Limited), Mumbai vs. Dy Commissioner of Income Tax, Central Circle 7(3) (Formerly Income Tax Officer, Ward 6(3)(2)), Mumbai

In the result, for A.Y. 2015-16, the appeal of the learned

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Macrotech Developers Ltd. (Successor To M/S Sahajanad Acit Cc-7(3) Hi-Tech Construction Pvt. Room No. 655, Ltd.) Aayakar Bhavan, 412,4Th Floor, 17-G, Vs. M.K.Road, Vardhaman Chambers, Mumbai- 400 020 Cawasji Patel Road, Horniman Cirlce, Fort, Mumbai-400001 (Respondent) (Appellant) Pan No.Aaecp1936F Acit Cc-7(3) Macrotech Developers Ltd. Room No. 655, (Successor To Bellissimo Aayakar Bhavan, Developers Thane Private Limited) M.K.Road, 412, Floor-4, 17G Vs. Mumbai- 400 020 Vardhman Chamber, Cawasji, Patel Road, Horniman Circle, Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D ‘Ita No. 1864/Mum/2022 (Assessment Year 2015-16) Macrotech Developers Ltd. Dcit, (Successor To Bellissimo Central Circle 7(3) Developers Thane Private Room No. 655, 6 Th Floor, Limited) 412, Floor-4, 17G Aaykar Bhavan, Vs. Vardhman Chamber, Cawasji, M. K. Road, Patel Road, Horniman Circle, Mumbai-400 021 Fort, Mumabi-400 001 (Respondent) (Appellant) Pan No.Aadco0409D

…as deduction in the return of income in the year of incurring those expenses, interest is periodic cost and therefore, same is claimed as deduction. Assessee relied upon the decision of Hon'ble Bombay High Court in CIT vs. Lokhandwala Construction Inds. Ltd. 260 ITR 579 (Bom). 06. The learned Assessing Officer rejected the contention of the assessee. He held that as per Accounting Standard (AS)-7 and Guidance Note on Accounting for Real Estate Transactions issued by the Institute of Chartered Accountants of India, all the expenses directly related to the project must be carried over as the cost of the project. I…

Dy. Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd (Successor to M/S Lodha Impression Real Estate Pvt Ltd), Mumbai

In the result, all the appeals of the revenue are dismissed

…d had to be allowed in the year of incurrence thereof as it admittedly pertains to the stock in trade of the assessee. The assessee relied on the decision of Hon’ble Jurisdictional High Court in the case of CIT vs Lokhandwala Construction Ind. Ltd reported in 260 ITR 579 (Bom) in support of its contentions. On the contrary, the ld. AO relied on the decision of Special Bench of Mumbai Tribunal in the case of M/s Wall Street Construction Ltd reported in 102 TTJ 505 (Mum) (SB) and disallowed the interest of Rs 5,00,78,994/- by capitalizing it to work in progress. 4.1. We find that the ld. CIT(A) had granted relief…

Assistant Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Macrotech Developers Ltd(Successor to M/S Lodha Impression Real Estate Pvt Ltd)., Mumbai

In the result, all the appeals of the revenue are dismissed

…d had to be allowed in the year of incurrence thereof as it admittedly pertains to the stock in trade of the assessee. The assessee relied on the decision of Hon’ble Jurisdictional High Court in the case of CIT vs Lokhandwala Construction Ind. Ltd reported in 260 ITR 579 (Bom) in support of its contentions. On the contrary, the ld. AO relied on the decision of Special Bench of Mumbai Tribunal in the case of M/s Wall Street Construction Ltd reported in 102 TTJ 505 (Mum) (SB) and disallowed the interest of Rs 5,00,78,994/- by capitalizing it to work in progress. 4.1. We find that the ld. CIT(A) had granted relief…

Assistant Commissioner of Income Tax, CC-7(3), Mumbai vs. M/S Mmr Social Housing Pvt Ltd (Earlier Know As M/S Lodha Buildcon Pvt Ltd), Mumbai

In the result, all the appeals of the revenue are dismissed

…d had to be allowed in the year of incurrence thereof as it admittedly pertains to the stock in trade of the assessee. The assessee relied on the decision of Hon’ble Jurisdictional High Court in the case of CIT vs Lokhandwala Construction Ind. Ltd reported in 260 ITR 579 (Bom) in support of its contentions. On the contrary, the ld. AO relied on the decision of Special Bench of Mumbai Tribunal in the case of M/s Wall Street Construction Ltd reported in 102 TTJ 505 (Mum) (SB) and disallowed the interest of Rs 5,00,78,994/- by capitalizing it to work in progress. 4.1. We find that the ld. CIT(A) had granted relief…

ACIT 1 (1)(1), Mumbai vs. M/S Dosti Realty Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

Bench: Shr Pramod Kumar, Vp & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 7374/Mum/2019 (निर्धारणवर्ा / Assessment Year: 2014-15) Asst. Commissioner Of M/S Dosti Realty Ltd. (Formally Known As Friends Income Tax-1(1)(1), Development Corporation 579,Ayankar Bhavan, M.K बिधम/ (Imperia) Pvt. Ltd. Road, Mumbai-400020, 276,1St Floor, Lawrence & Vs. Mayo House, Mumbai - 400001, स्थायीलेखासं./जीआइआरसं./ Pan No Aabcf5801A (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri P.R. Rastogi, Ld. Dr प्रत्यथीकीओरसे/Respondent By : Shri Dr.K.Shivaram & Rahul Hakani, Ld. Ar सुनवाईकीतारीख/ : 14.06.2022 Date Of Hearing घोषणाकीतारीख / : 06.09.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Revenue Against Order Dated 19.09.2019, Passed By Ld. Cit (Appeals)-2, Mumbai For The Quantum Of Assessment Passed U/S 143(3) For Ay 2014-2015. The Revenue Has Raised The Following Grounds:-

…sti Imperia have been capitalized by the assessee. The amount of interest of Rs 15.04 crore did not pertain to any asset, therefore the same has not been capitalized. The Hon’ble Bombay High Court in the case of CIT v Lokhandwala Construction Inds. Ltd (2003) 260 ITR 579 (Bom)(HC), it was held that deduction of interest u/s 36(l)(iii) was allowable when capital was borrowed for obtaining stock in trade and not fixed Asset. The relevant portion of the judgement reads as under:- "In the present case, the assessee had undertaken the Project of construction of flats under the Kandivali Project. Therefore, the loan w…

DCIT CC 7(3), Mumbai vs. M/S Palava Dwellers Pvt. Ltd., Mumbai

In the result, appeal filed by the learned AO is dismissed and appeal of the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

…ther on the fact and circumstances of the case and in law, the Ld. CIT(A) was correct while deleting the addition of Rs.2,24,11,60,000/- relied upon the decision of the judgment of the jurisdictional High Court in the case of Lokhandwala Construction Inds Ltd 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003. 3. "On the facts and circumstances of the case and in law, the Ld. CIT(A) was correct while deleting the addition of Rs. 1,55,33,306/- that no exempt income was earned during the year, thereby ignoring the CBDT Circular no. 5 of 2014 dated 11.…

Lodha Developers Ltd.(Successor to Palava Dwellers Pvt. Ltd.), Mumbai vs. DCIT, CC- 7(3), Mumbai

In the result, appeal filed by the learned AO is dismissed and appeal of the assessee is allowed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

…ther on the fact and circumstances of the case and in law, the Ld. CIT(A) was correct while deleting the addition of Rs.2,24,11,60,000/- relied upon the decision of the judgment of the jurisdictional High Court in the case of Lokhandwala Construction Inds Ltd 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003. 3. "On the facts and circumstances of the case and in law, the Ld. CIT(A) was correct while deleting the addition of Rs. 1,55,33,306/- that no exempt income was earned during the year, thereby ignoring the CBDT Circular no. 5 of 2014 dated 11.…

Tata Housing Development Company Ltd., Mumbai vs. DCIT- 8(3)(1), Mumbai

In the result, the appeal filed by the assessee ITA

Bench: Shri Pavan Kumar Gadale & Shri Amarjit Singhm/S Tata Housing Vs. Dcit – 8(3)(1) Development Company Room No. 615, Ltd.,E Block, Voltas Aayakar Bhavan, Compound, Tb Kadam Mk Marg, Marg, Chinchpokli, Mumbai – 400020. Mumbai – 400033. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. :Aaact0191Q Appellant .. Respondent Dcit – 8(3)(1) Vs. M/S. Tata Housing Room No. 615, Aayakar Development Company Bhavan, Ltd.,E Block, Voltas Mk Marg, Compound, Tb Kadam Mumbai – 400020. Marg, Chinchpokli, Mumbai – 400033. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. :Aaact0191Q Appellant .. Respondent

…be allowed till the project is complete and revenue recognized - thus this ground of appeal is dismissed. Reliance placed by Ld. Counsel on the following decisions: (i) Tata Chemicals Ltd. 256 ITR 395 (ii) CIT Vs. Lokhandwala Constructions India Ltd. (2003) 260 ITR 579. (iii) Paranjape Griha Ninnan P. Ltd. Vs. Jt. C1T Spl Rg, 50 in ITA No. 2398/Mum/2001 dated 04-04-2006. (iv) Jt. CIT Spl Rg. 6 Vs. K. Raheja (P) Ltd. 102ITD 414. Is of no avail because in all these cases what has been decided is the fact of allowability of 'interest” as a 'period cost - which is not in doubt here- what is assailed is that 'projec…

Lodha Developers Ltd(Formerly Known As Lodha Developers Private Limited), Mumbai vs. DCIT Cen Cir 7(3), Mumbai

In the result, appeal filed by the revenue is dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Blemacrotech Developers Limited V. Dcit – Central Circle – 7(3) {Erstwhile Lodha Developers Limited} Room No. 655, 6Th Floor 412, 4Th Floor, 17G Vardhaman Chamber Aayakar Bhavan, M.K. Road Cawasji Patel Road, Horniman Circle Mumbai – 400020 Fort, Mumbai - 400001 Pan: Aaacl1490J (Appellant) (Respondent) Dcit – Central Circle – 7(3) V. Macrotech Developers Limited Room No. 655, 6Th Floor {Erstwhile Lodha Developers Limited} 412, 4Th Floor, 17G Vardhaman Chamber Aayakar Bhavan, M.K. Road Cawasji Patel Road, Horniman Circle Mumbai – 400020 Fort, Mumbai - 400001 Pan: Aaacl1490J (Appellant) (Respondent)

…2. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) is deleting the addition of Rs.58,99,99,069/- relied upon the decision of the judgement of the jurisdictional High Court in the case of Lokhandwala Construction India Ltd. 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003?” “3. Whether on the facts and in the circumstances of the | case and in law, the Ld. CIT(A) erred in deleting the addition of Rs.15,17,14,879/- made by the Assessing Officer u/s 14A r.w.r. 8D and limiting the disallowance made by the Assessing…

DCIT CC 7(3), Mumbai vs. M/S Cowtown Land Development Pvt. Ltd., Mumbai

In the result, the appeal filed by the revenue is dismissed

…placed on the decision of the Hon'ble Supreme Court in the case of Taparia Tools Pvt. Ltd., v. JCIT in Civil Appeal No. 6366/2003 dated 23.03.2015 and the decision of the Hon'ble Bombay High Court in the case of CIT v.LokandwalaConstruction Industries Ltd., [260 ITR 579]. 4. Not convinced with the submissions of the assessee, the Assessing Officer placing reliance on the judgement of the Hon'ble Special Bench, Mumbai in the case of M/s. Wall Street Construction Limited [102 TTJ 505] wherein it has been held that the interest cost shall be debited to work in progress and allowed to be claimed as deduction only i…

DCIT Cen Cir 7(3), Mumbai vs. Sanathanagar Enterprises Ltd, Mumbai

In the result and subject to the above observation, all the three appeals are dismissed

…g the addition of Rs.7,77,81,219/- relied upon the decision of the judgement of the jurisdictional High Court in the case of Lokhandwala ITA Nos. 792, 793 and 794/Mum/ 2019 Assessment years: 2013-14, 2014-15 and 2015-16 Page 2 of 11 Construction Inds. Ltd. 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003.” 3. The issue in the appeal lies in a very narrow compass of material facts. The assessee is engaged in the business of real estate construction and development. The assessee is following the mercantile system of accounting and, so far as rec…

DCIT Cen Cir 7(3), Mumbai vs. Sanathanagar Enterprises Ltd, Mumbai

In the result and subject to the above observation, all the three appeals are dismissed

…g the addition of Rs.7,77,81,219/- relied upon the decision of the judgement of the jurisdictional High Court in the case of Lokhandwala ITA Nos. 792, 793 and 794/Mum/ 2019 Assessment years: 2013-14, 2014-15 and 2015-16 Page 2 of 11 Construction Inds. Ltd. 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003.” 3. The issue in the appeal lies in a very narrow compass of material facts. The assessee is engaged in the business of real estate construction and development. The assessee is following the mercantile system of accounting and, so far as rec…

DCIT Cen Cir 7(3), Mumbai vs. Sanathanagar Enterprises Ltd, Mumbai

In the result and subject to the above observation, all the three appeals are dismissed

…g the addition of Rs.7,77,81,219/- relied upon the decision of the judgement of the jurisdictional High Court in the case of Lokhandwala ITA Nos. 792, 793 and 794/Mum/ 2019 Assessment years: 2013-14, 2014-15 and 2015-16 Page 2 of 11 Construction Inds. Ltd. 260 ITR 579 the same were rendered before the proviso to section 36(1)(iii) has been inserted vide Finance Act 2003.” 3. The issue in the appeal lies in a very narrow compass of material facts. The assessee is engaged in the business of real estate construction and development. The assessee is following the mercantile system of accounting and, so far as rec…

Mmr Social Housing P. Ltd., Mumbai vs. Dy CIT-Central Range-7(3), Mumbai

In the result, appeal by the assessee is allowed in terms of our aforesaid findings

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

…td. ITA No.1310/Mum./2021 6. In appeal before the CIT(A), assessee, inter-alia, submitted that the issue is covered in favour of the assessee by decision of Hon’ble Jurisdictional High Court in case of CIT v/s Lokhandwala Construction Industries Ltd.: [2003] 260 ITR 579. The CIT(A) vide impugned order dated 20 May 2021 held that the aforesaid decision of Hon’ble Jurisdictional High Court was on a different issue and thus is not applicable to the present case. The CIT(A) further held that the issue was considered by Special Bench of Tribunal in Wall Street Construction Ltd. (supra) and same is applicable to the f…

Asstt. CIT (OSD) - CC -7 (3), Mumbai vs. M/S. Macrotech Developers Ltd. (Earlier Known As M/S Lodha Developers Ltd.), Mumbai

In the result the appeal filed by the assessee is allowed for statistical purposes

Bench: S Shri Rifaur Rahamn & Pavan Kumar Gadaledcit – Cc-7(3) Vs. Macrotech Developers Room No. 655, 6Th Ltd (Successor To Floor, Aayakar Bhavan, Bellissimo Crown Mk Road, Mumbai – Buildmart Pvt Ltd) 400020. (Earlier Known As Lodha Crown Build Mart Ltd) 412, 17-G, Vardhaman Chambers, Cp Road, Horniman Circle Fort, Mumbai – 400001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacl1490J Appellant .. Respondent Macrotech Developers Vs. Dcit – Cc-7(3) Ltd (Successor To Room No. 655, 6Th Bellissimo Crown Floor, Aayakar Bhavan, Buildmart Pvt Ltd) Mk Road, Mumbai – (Earlier Known As 400020. Lodha Crown Build Mart Ltd) 412, 17-G, Vardhaman Chambers, Cp Road, Horniman Circle Fort, Mumbai – 400001. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacl1490J Appellant .. Respondent

…the Ld. CIT(A) erred in deleting the addition of Rs. ITA.no.2387,2336,131&68/Mum/2019 Macrotech Developers Ltd, Mumbai. 66,45,29,655/- relied upon the decision of the judgment of the jurisdictional High Court in the case of Lokhandwala Constructions Ind Ltd 260 ITR 579 the same were rendered before the proviso to Sec 36(1)(iii) has been inserted vide Finance Act 2003. 3. Whether on the fact and circumstances of the case and in law, the Ld. CIT(A) erred in deleting the addition of Rs. 14,06,26,48/- made by the A.O u/s 14A r.w.r 8D and limiting the disallowance made by the AO to the extent of exempt income of the…

M/S Fortune Rpj Developers, Thane vs. ACIT Circle-1, Thane

In the result, the appeal of the assessee is dismissed

Bench: Shri Om Prakash Kant () & Shri Pavan Kumar Gadale ()

…ction 36(1)(iii) of the Act, interest should be allowed on borrowings taken for the purpose of the business. The learned counsel of the assessee has relied on the decision of the Hon’ble Bombay High Court in the case of Lokhandwala Construction Industries Ltd 260 ITR 579, which was also relied before the Ld. CIT(A). The Hon’ble High Court in the said case summed up their decision as under: “31. For the reasons discussed above, we hold that where an assessee is following project-completion method of accounting, the interest identifiable with that project should be allowed only in the year when the project is comp…