IT : Conversion of interest payable into equity shares is 'actual payment' for the purposes of section 43(1)(d) since it is discharge of liability and is not mere deferment of liability as contemplated under Explanation 3C to section 43B. Explanation 3C would apply only to deferment of interest liability by conversion into FITL and not where interest liability is discharged by any mode including by conversion into equity shares
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