ITAT Upholds CIT(A) Decision Allowing Section 11 Deduction, Citing Consistency Despite Payments u/s 13(1)(c.

The ITAT upheld the CIT(A)'s order allowing deduction u/s 11, following the 'Principle of Consistency'. Despite payments to specified persons u/s 13(1)(c), the Revenue had allowed exemption in earlier years without adverse remarks. Applying Radhasoami Satsang, the ITAT ruled that without a change in facts or the earlier order being arbitrary/perverse, the Revenue cannot deviate from its consistent stance in subsequent years. Certainty and finality are essential, mandating consistent treatment unless material differences exist. The DR failed to demonstrate any infirmity or factual changes, leading to the decision against the Revenue. .....

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