Case Law Analysis
|Income Tax Appellate Tribunal
Consistency Principle Bars Deemed Interest Addition on Slump Sale Advances | ITAT Delhi
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.