How do you INCLUDE subscripts in linker file (.ld file)?

I have successfully included a separate .ld file into my main .ld file like this

INCLUDE memory.ld

Now I want to include another .ld file within the SECTIONS area e.g.

SECTIONS
{
    .foo {...}
    .bar {...}
    ...

    INCLUDE dwarf.ld
}

The documentation explains this should be possible - I think?

You can place INCLUDE directives at the top level, in MEMORY or SECTIONS commands, or in output section descriptions.

However, I am getting this error:

ld: error: /home/project/link_file.ld:198: malformed number: dwarf.ld
>>>   INCLUDE dwarf.ld
>>>           ^

Is it possible to do something like this? Does anyone have any suggestion why this message comes up?

Thanks