Accrued interest on assigned debt held not taxable where identical issue had already been decided on the same facts.

Interest said to have accrued on assigned debt was treated by the Tribunal as not taxable in the assessee's hands on an accrual basis, because the same issue had already been decided in the assessee's own case for earlier years on identical facts. With no distinguishing change shown, the coordinate bench view was followed and the interest addition was held unsustainable. The revenue's challenge to the deletion of the addition therefore failed, and the assessment was not restored.

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Issues: Whether interest claimed to have accrued on assigned debt was taxable in the assessee's hands on accrual basis.

Analysis: The disputed addition arose from the revenue's treatment of interest said to have accrued on the assigned debt as income from other sources. The Tribunal noted that the same question had already been decided in the assessee's own case for earlier years and that there was no change in facts. Following the coordinate bench decisions, the issue was treated as covered in favour of the assessee.

Conclusion: The addition on account of accrued interest was not sustainable and the issue was decided in favour of the assessee.

Final Conclusion: The revenue's challenge to the deletion of the interest addition failed, and the assessment order was not restored.

Ratio Decidendi: Where an identical issue has already been decided in the assessee's own case on the same facts, and no distinguishing change is shown, the earlier view should be followed and the corresponding addition cannot be sustained.

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