Conversion of unpaid interest into loan not amounts to deemed payment of interest U/s. 43B

Teesta Agro Industries Ltd. Vs. DCIT (ITAT Kolkata) It is not in dispute that the unpaid interest has been converted/rescheduled into fresh loan. The assessee had only made a claim u/s 43B of the Act as deduction passed on constructive payment of interest to the bank and constructive receipt thereon from the bank as loan. But we find that the provisions of Explanation 3C to section 43B of the Act are against the assessee which reads as under:- “[ Explanation 3C- For the removal of doubts, it is hereby declared that a deduction of any sum, being interest payable under clause (d) of this secti...