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and not a "contractor", sums received as advances by it were not under a "construction contract" and the Assessee was not following the 'Percentage of Completion Method' ('POCM'). He states that the ITAT itself made the self-contradictory finding that the respondent was following the "completed contract method" ('CCM'). Therefore, the said expenses being capital in nature should have been disallowed in accordance with provisions of Section 37(1) of the Act. He states that the ITAT failed to appreciate that the expenses incurred by the Assessee were not intended to earn revenue during the subject AY and were spent for an 'enduring benefit' of the real estate project over a significant period of time, consisting of a number of AYs till the completion and sale of the project.