#Consistency Principle

ITAT Delhi rules that the Revenue cannot reopen settled tax positions for identical facts across assessment years without a material change in circumstances. The tribunal upheld a 1% addition on gross bank transactions, rejecting arbitrary reassessment attempts, reinforcing binding precedent for taxpayers and tax authorities.

ITAT Delhi deleted a Rs. 10.15 crore deemed interest addition on interest-free advances acquired through a slump sale, holding that the Revenue’s long-standing acceptance of such advances in prior years precludes retrospective disallowance. This reinforces commercial expediency and consistency as binding limits on tax authorities, protecting businesses that structure group financing through asset acquisitions.

ITAT Delhi ruled that a limited risk service provider is entitled to cost-plus remuneration, rejecting transfer pricing adjustments where benchmarking was inconsistent and DRP directions were ignored. The decision reinforces the consistency principle in transfer pricing, impacting multinational enterprises and tax compliance strategies.