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“rule of consistency”

Judicial DoctrinesRadhasoamiRadhasoami1,041 judgments

The decision most relied on for rule of consistency is M/s Sahara India (Farms) v. CIT & Anr. (300 ITR 403), cited in 268 judgments on BharatTax.

Leading authorities on rule of consistency

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

Administrative orders must be consistent with the rules of natural justice.

DIT (E) v. Apparel Export Promotion Council
245 ITR 492 · 2000 · High Court
193
citing judgments

The rule of consistency applies when facts or legal positions remain unchanged in earlier assessment years, preventing the Revenue from adopting a divergent stance in subsequent years without new material. This ensures stability and predictability in tax assessments.

Munjal Sales Corporation v. CIT
298 ITR 298 · 2008 · Supreme Court
191
citing judgments

The Supreme Court approves the mixed fund theory, holding that no interest disallowance is warranted under section 36(1)(iii) if investments or advances are made from the assessee's own non-interest bearing funds, even when mixed funds are available. This presumption applies when non-interest bearing funds are sufficient to meet the investments.

(i) Sultana Begum v. Prem Chand Jain
1 SCC 373 · 1997 · Reported
187
citing judgments

A statute must be read as a whole, construing every clause with reference to its context and other provisions, to determine the legislature's real intention and ensure a consistent enactment. This principle, known as "ex visceribus actus," helps avoid inconsistencies within the law.

Berger Paints India Ltd. v. CIT
266 ITR 99 · 2004 · Supreme Court
181
citing judgments

The Revenue cannot take a conflicting stand from what it had earlier accepted in a previous assessment year without compelling justification. This principle of consistency applies to various issues, including the treatment of customs duty in closing inventory.

Radhasoami Satsang v. CIT
244 ITR 734 · 2000 · High Court
168
citing judgments

The Revenue is bound by the rule of consistency and cannot adopt a divergent position in a subsequent assessment year unless there is a change in facts or law.

Krishak Bharati Cooperative Ld v. DCIT
23 Taxmann.com 265 · 2012 · High Court
147
citing judgments

The rule of consistency does not override the correct application of law and should not be applied if it leads to an anomalous outcome.

Bharat Sanchar Nigam Ltd. v. Union of India
282 ITR 273 · 2006 · Supreme Court
136
citing judgments

The rule of consistency requires that in the absence of any change in material facts or law, a different view or decision on an issue cannot be adopted for subsequent assessment years, thus ensuring uniformity in tax assessments.

Judgments citing rule of consistency

Urja Properties Pvt. Ltd., Jagdalpur vs. Income Tax Office, Jagdalpur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 232/RPR/2026[2014-15]Status: DisposedITAT Raipur09 Apr 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.232/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 Urja Properties Private Limited Bms House, Motitalab Para, Jagdalpur (C.G.)-494 001 Pan: Aabcu6244N

For Appellant: Shri R.B Doshi, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... Urja Properties Private Limited Vs. ITO, Jagdalpur (C.G.) 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the order of the Ld. CIT(Appeals) and remand the matter back to his file for denovo adjudication while complying with

Vikash Chhatri, Bilaspur vs. Income Tax Officer, Ward-1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 230/RPR/2026[2017-18]Status: DisposedITAT Raipur09 Apr 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.226, 227, 228, 229 & 230/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 To 2017-18 Vikas Chhatri Santosh Egg Centre, Vyapar Vihar, Bilaspur (C.G.)-495 001 Pan: Avqpc8070K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Ms. Namrata Kayarwar, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to his file for denovo adjudication while complying with

Vikash Chhatri, Bilaspur vs. Income Tax Officer, Ward-1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 229/RPR/2026[2016-17]Status: DisposedITAT Raipur09 Apr 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.226, 227, 228, 229 & 230/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 To 2017-18 Vikas Chhatri Santosh Egg Centre, Vyapar Vihar, Bilaspur (C.G.)-495 001 Pan: Avqpc8070K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Ms. Namrata Kayarwar, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to his file for denovo adjudication while complying with

Vikas Chhatri, Bilaspur vs. ITO, Ward-1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 228/RPR/2026[2015-16]Status: DisposedITAT Raipur09 Apr 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.226, 227, 228, 229 & 230/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 To 2017-18 Vikas Chhatri Santosh Egg Centre, Vyapar Vihar, Bilaspur (C.G.)-495 001 Pan: Avqpc8070K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Ms. Namrata Kayarwar, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to his file for denovo adjudication while complying with

Vikas Chhatri, Bilaspur vs. ITO, Ward-1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 227/RPR/2026[2014-15]Status: DisposedITAT Raipur09 Apr 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.226, 227, 228, 229 & 230/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 To 2017-18 Vikas Chhatri Santosh Egg Centre, Vyapar Vihar, Bilaspur (C.G.)-495 001 Pan: Avqpc8070K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Ms. Namrata Kayarwar, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to his file for denovo adjudication while complying with

Vikas Chhatri, Bilaspur vs. ITO, Ward-1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 226/RPR/2026[2013-14]Status: DisposedITAT Raipur09 Apr 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.226, 227, 228, 229 & 230/Rpr/2026 "नधा"रण वष" /Assessment Years : 2013-14 To 2017-18 Vikas Chhatri Santosh Egg Centre, Vyapar Vihar, Bilaspur (C.G.)-495 001 Pan: Avqpc8070K .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Ward-1(1), Bilaspur (C.G.) ……""यथ" / Respondent

For Appellant: Ms. Namrata Kayarwar, CAFor Respondent: None (Petition filed)
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to his file for denovo adjudication while complying with

Bharat Kumar Agrawal, Raipur vs. ITO, Ward-4(1), Raipur

In the result, all the appeals of the assessee are

ITA 110/RPR/2026[2022-23]Status: DisposedITAT Raipur20 Mar 2026AY 2022-23

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.110/Rpr/2026 निर्धारण वर्ष / Assessment Year : 2022-23 Bharat Kumar Agrawal Opp. Om Hospital, Purani Basti, Raipur (C.G.) Pan: Acjpa4289L ........अपीलार्थी / Appellant बनाम / V/S. The Income Tax Officer, Ward-4(1), Raipur (C.G.) ......प्रत्यर्थी / Respondent Assessee By : Shri Prafulla Pendse, Ca Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 20.03.2026 घोषणा की तारीख / Date Of Pronouncement : 20.03.2026 2 Bharat Kumar Agrawal Vs. Ito, Ward-4(1), Raipur (C.G.)

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250

within three months from receipt of this order." 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... appeals of the assessee are allowed for statistical purposes.” Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file for denovo adjudication while complying

M/S Shree Associates, Raigarh vs. ACIT, Central Circle, Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 124/RPR/2026[2013-14]Status: HeardITAT Raipur19 Mar 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.124/Rpr/2026 "नधा"रण वष" / Assessment Year : 2013-14 M/S. Shree Associates Ward No.14, Kotra Road, Raigarh-496 001 (C.G.) Pan: Abtfs9583J

For Appellant: NoneFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(4)

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 6. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the order of the Ld. CIT(Appeals) and remand the matter back to its file for denovo adjudication 10 M/s. Shree Associates

Prakash Kumar Chawla, Bilaspur vs. Assistant Commissioner of Income Tax Circle 1(1) Bilaspur, Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 123/RPR/2026[2020-21]Status: HeardITAT Raipur19 Mar 2026AY 2020-21

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं./Ita No.123/Rpr/2026 "नधा"रण वष" /Assessment Year : 2020-21 Prakash Kumar Chawla Telipara, Bilaspur-495 001 (C.G.) Pan: Aappc2370L

For Appellant: None (petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 6. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file for denovo adjudication while complying with

J.R.P. Builders & Developers, Raipur vs. Income Tax Officer (TDS), Raipur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 252/RPR/2023[2018-19]Status: DisposedITAT Raipur19 Mar 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.252/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 J.R.P Builders & Developers Quarter No.4, Road No.1, Sector-01, Professor Colony, Raipur-492 001 Pan: Aanfj6828Q

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250(4)

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 4. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the order of the Ld. CIT(Appeals)/NFAC and remand all the grounds of appeal back to its file for denovo adjudication

Rekha Chandrakar, Dhamtari vs. ACIT, Central Circle-2, Raipur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 187/RPR/2026[2023-24]Status: DisposedITAT Raipur18 Mar 2026AY 2023-24

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.187/Rpr/2026 "नधा"रण वष" /Assessment Year : 2023-24 Smt. Rekha Chandrakar C/O. Jyoti Enterprises, Megha Road, Kurud-493 663 Dhamtari (C.G) Pan: Auypc9672Q

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(4)

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file for denovo adjudication as per law while

Shivansh Enterprises, Bhilai, Durg vs. Income Tax Officer-2(1), Bhilai, Durg

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 182/RPR/2026[2016-17]Status: DisposedITAT Raipur18 Mar 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.182/Rpr/2026 "नधा"रण वष" /Assessment Year : 2016-17 Shivansh Enterprises Plot No.11-H, Hathkhoj, Heavy Industrial Area, Bhilai-490 026 (C.G.) Pan: Abafs3020K

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 250(4)

Shivansh Enterprises Vs. ITO-2(1), Bhilai (C.G.) 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file for denovo adjudication as per law while

M/S Gindlani Rice Mill, Raipur vs. Income Tax Officer-1(2), Raipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 814/RPR/2025[2016-17]Status: DisposedITAT Raipur18 Mar 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita Nos.813 & 814/Rpr/2025 "नधा"रण वष" / Assessment Years : 2014-15 & 2016-17 M/S. Gindlani Rice Mill Tilda Neora, Village-Tulsi, Raipur (C.G.)-493 114 Pan: Aadfg6455G ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: None (petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 36(1)(iii)

assessee is allowed for statistical purposes.” 7. Respectfully following the aforesaid judicial pronouncement, on same parity of reasoning and while maintaining rule of consistency as per similar terms, we set aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file with similar direction

M/S Gindlani Rice Mill, Raipur vs. Income Tax Officer-1(2), Raipur

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 813/RPR/2025[2014-15]Status: DisposedITAT Raipur18 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita Nos.813 & 814/Rpr/2025 "नधा"रण वष" / Assessment Years : 2014-15 & 2016-17 M/S. Gindlani Rice Mill Tilda Neora, Village-Tulsi, Raipur (C.G.)-493 114 Pan: Aadfg6455G ........अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-1(2), Raipur (C.G.) ……""यथ" / Respondent

For Appellant: None (petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(3)Section 36(1)(iii)

assessee is allowed for statistical purposes.” 7. Respectfully following the aforesaid judicial pronouncement, on same parity of reasoning and while maintaining rule of consistency as per similar terms, we set aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file with similar direction

M/S Chandrahasni Ispat Pvt. Ltd., Raigarh vs. ACIT-Circle 1(1), Bilaspur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 700/RPR/2025[2016-17]Status: DisposedITAT Raipur18 Mar 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Shri Avdhesh Kumar Mishraआयकर अपील सं. / Ita No.700/Rpr/2025 "नधा"रण वष" / Assessment Year : 2016-17 M/S. Chandrahasni Ispat Private Limited Village-Gerwani, Sarapali Road, Raigarh (C.G.)-496 001 Pan: Aaccc9257G

For Appellant: None (Petition filed)For Respondent: Shri Raghunath, CIT-DR
Section 250(4)

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 6. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set-aside the order of the Ld. CIT(Appeals)/NFAC and remand the matter back to its file for denovo adjudication as per law while

M.K. Gupta and Sons HUF, C/O Ca Sahil Gupta vs. ITO Ward 59(6), Income Tax Department

In the result, appeal of the assessee is allowed for statistical purposes

ITA 915/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Mar 2026AY 2017-18

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 143(3)Section 250Section 68Section 69A

accepted the modus operandi of the appellant and the only question there was the rate of the commission which was disputed, therefor the rule of consistency should be applied. 7. That on the facts and in the circumstances of the case and in law, Id CIT-A erred in sustaining

Home Credit International A.S., Czech Republic vs. Assistantdeputy Commissioner of Income Tax International Taxation, Gurgaon Haryana

In the result, the appeal of the assessee is allowed

ITA 3846/DEL/2023[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri Vikas Awasthy, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

Section 143(3)Section 144CSection 144C(8)Section 153Section 282

various services provided to Indian group entities 18. Now, reverting back to the first part of learned Senior Counsel's argument that applying rule of consistency, the Assessing Officer cannot re-characterize the receipts as FTS, as, in the earlier assessment years, he has consistently treated identical receipts as royalty ... Therefore, the action of the Assessing Officer in characterizing the receipts as FTS cannot be called into question by advancing the theory of rule of consistency. Thus, in our view, the judicial precedents cited before us by learned Senior Counsel would be of no help to the assessee, as, what

Dcm Shriram Industris Ltd, New Delhi vs. DCIT Circle-7(1), New Delhi

In the result, the appeal filed by the assessee is allowed in above terms

ITA 2166/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Mar 2026AY 2018-19

Bench: Shri Challa Nagemdra Prasad & Shri S. Rifaur Rahman

Section 115JSection 143(3)Section 144C(10)Section 14ASection 80Section 92C

DRP/TPO and consequently the Ld. AO have erred in law and on facts and circumstances of the case in not following rule of consistency by disregarding that same methodology has been followed by appellant since assessment year 2006-07 which has also been approved ... issue has been accepted at that level. It was thus submitted that adjustment on account transfer of steam should be deleted following the rule of consistency. Several judgements as listed below were relied upon by the ld.AR in support of this contention: - a. CIT v. GE India Technology Centre

Accurate Ashray Pvt. Ltd., Howra vs. DCIT, Central Circle-1, Raipur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 178/RPR/2026[2014-15]Status: DisposedITAT Raipur17 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.177 & 178/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 Accurate Ashray Private Limited Ward No.39, Holding No. Koyla Dept. 28 No, Gali, P.S. Shibpur, Howrah-711 102 Pan: Aagca9943F

For Appellant: S/Shri Praveen Jain &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to its file for denovo adjudication as per law while

Accurate Ashray Pvt. Ltd., Howra vs. DCIT, Central Circle-1, Raipur

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 177/RPR/2026[2014-15]Status: DisposedITAT Raipur17 Mar 2026AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.177 & 178/Rpr/2026 "नधा"रण वष" /Assessment Year : 2014-15 Accurate Ashray Private Limited Ward No.39, Holding No. Koyla Dept. 28 No, Gali, P.S. Shibpur, Howrah-711 102 Pan: Aagca9943F

For Appellant: S/Shri Praveen Jain &For Respondent: Dr. Priyanka Patel, Sr. DR
Section 250

within three months from receipt of this order.” 8. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, we set- aside the respective orders of the Ld. CIT(Appeals)/NFAC and remand the matters back to its file for denovo adjudication while ... assessee are allowed for statistical purposes.” 5. Respectfully following the aforesaid order, on the same parity of reasoning and as per rule of consistency, I set-aside the respective orders of the Ld. CIT(Appeals) and remand the matters back to its file for denovo adjudication as per law while