Consistent Treatment Principle Upheld: ITAT Allows Deduction Despite Payments to Specified Persons.

The ITAT upheld the CIT(A)'s decision to allow a deduction under section 11, emphasizing the 'Principle of Consistency.' Despite payments to specified persons under section 13(1)(c), the Revenue had previously allowed exemptions without objections. Citing Radhasoami Satsang, the ITAT ruled that in the absence of changed facts or arbitrary earlier rulings, the Revenue must maintain its consistent approach in subsequent years. The DR failed to show any factual changes or errors, resulting in a decision against the Revenue, reinforcing the necessity for certainty and finality in tax treatment. .....

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