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2. Whether the Tribunal erred in the facts and circumstances of the case and prevailing law in holding that Internal Development Costs/ External Development Costs have to be included for the purposes of computing threshold limit for recognition Revenue under the POCM?
3. Whether the Tribunal erred in the facts and circumstances of the case and prevailing law in deleting the addition of Rs.91,70,13,955/- on account of capitalization of interest expense as per AS-16?

5. We thus find no justification to interfere with the view as expressed by the Tribunal.

6. The second aspect which was sought to be canvassed for our consideration pertained to the treatment of Internal Development Charges and External Development Charges and whether they were liable to be included for the purposes of computation of the threshold limit for recognizing revenue under the POCM. While dealing with IDC the Tribunal has ultimately observed as under: