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TMI Blog2023 (5) TMI 549X X X X Extracts X X X X X X X X Extracts X X X X ..... the goose is sauce for the gander. The approach of the AO bordered on whimsicality. While we are conscious that the principle of res judicata has no place in the Income Tax regime, the principle of consistency, which is equally weighty, has been applied by the court where circumstances are pari materia with the facts obtaining in the period in issue. Accordingly, we find no reason to inte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pondent/assessee, does not oppose the prayer made in the application. 4. The prayer made in the application is, accordingly, allowed. The delay is condoned. 5. The application is disposed of, in the aforesaid terms. 6. This appeal concerns Assessment Year (AY) 2014-15. 7. The issue which arises for consideration in the instant appeal also arose in another appeal concerning respondent/a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . Before us, Learned AR has pointed out that in A.Y. 2011-12, assessee had taken on seconded employees who were originally employee in the flagship group company i.e. Godfrey Philips India (P) Ltd. and then seconded to the assessee on cost to company basis, without any mark-up. It has been further pointed by the Learned AR that no disallowance of secondment cost to employees was disallowed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat of ITA No. 2987 /Del/2018. We have hereinabove while deciding the appeal for A.Y. 2013-14 in ITA No. 2987 /Del/2018 and for the reasons stated therein have dismissed the grounds of Revenue. We for similar reasons dismiss the grounds of Revenue in the present appeal also. Thus the grounds of Revenue are dismissed. 10. It is not the case of the appellant/revenue that the findings of fact a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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