Principle of consistency defeats disallowance of secondment costs where factual findings were accepted and no perversity was shown.

Secondment costs were upheld as deductible where the Tribunal found they were actually incurred, had been accepted in earlier assessment years, and the Revenue failed to show any infirmity in those factual findings. The High Court found no perversity in the record and held that the Assessing Officer's partial disallowance lacked rationale. Applying the principle of consistency, it noted that the relevant year was pari materia with earlier years in which the same expenditure had been allowed. No substantial question of law arose, and the Revenue's challenge to deletion of the disallowance failed.

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Issues: Whether the Revenue's appeal against deletion of the disallowance of secondment costs gave rise to any substantial question of law.

Analysis: The Tribunal had upheld the CIT(A)'s deletion of the addition after finding that the secondment costs were actually incurred, had been accepted in earlier assessment years, and that the Revenue had not pointed out any infirmity in the factual findings. The Court found no perversity in those findings and held that the Assessing Officer's partial disallowance lacked rationale. The Court also applied the principle of consistency, noting that the factual position in the relevant year remained pari materia with earlier years in which the expenditure had been allowed.

Conclusion: No substantial question of law arose, and the Revenue's challenge to the deletion of the disallowance failed.

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