Principle of consistency bars Revenue's challenge to long-settled tax treatment of option price contribution.

The disputed tax treatment of "Option Price Contribution" had been consistently decided in favour of the assessee across assessment years 2002-03 to 2023-24, and the Tribunal had followed the same view. As no distinguishing feature was shown for the years in question, the Court applied the principle of consistency and declined to entertain the Revenue's appeals. The result was that the prior favourable treatment for the assessee was left undisturbed and the appeals were dismissed.

---

---

Issues: Whether the Revenue's appeals concerning tax treatment of "Option Price Contribution" were liable to be entertained when the issue had already been consistently decided in favour of the assessee across multiple assessment years.

Analysis: The Court noted that the question had been answered in favour of the assessee from assessment years 2002-03 to 2023-24, and that the Income Tax Appellate Tribunal had also taken the same view. No distinguishing feature was shown for the assessment years involved in the present batch. In these circumstances, the Court applied the principle of consistency and found no justification to admit the appeals.

Conclusion: The issue was decided in favour of the assessee, and the Revenue's appeals were dismissed.

Final Conclusion: The Court declined to interfere with the consistent view already taken on the disputed tax issue and brought the matter to an end by dismissing the appeals.

Ratio Decidendi: Where a tax issue has been consistently and repeatedly decided in favour of the assessee for earlier assessment years and no distinguishing feature is shown for the years under consideration, the principle of consistency may justify dismissal of the Revenue's appeal.

---