Addition on interest expenditure - principle of “consistency” - interest in the nature of penalty - when...

Addition on interest expenditure - principle of “consistency” - interest in the nature of penalty - when on identical facts, the Department has not made any disallowance in respect of interest payments, which the assessee has been consistently paying over a period of 10 years i.e. both in the past years as well as for the future assessment years, then the Department is precluded from making disallowance on the same set of facts in the impugned year under consideration. - AT .....

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