Disallowance of interest on loan on Plant & Machinery and Capital WIP by capitalizing it is unsustainable

DCIT Vs GNA Duraparts Ltd (ITAT Amritsar) Facts- AO noticed that the assessee has made an addition to fixed assets of INR 53,06,14,928/- and has also taken a new term loan of INR 28,41,66,284/- from the Central Bank of India. AO made an addition of an Addition of INR 2,86,84,840/-. Further, the interest amounting to INR 51,24,000/- interest paid on the purchase of machinery is disallowed from revenue expenses and is capitalized into Machinery under installation. Additionally, the interest paid on the loan to the addition of the building under construction and for the new term loan for the buil...