TaxTMI 
TaxTMI 
Sir
If interest expences are allowed in past assessments years u/s 143(3), whether consistency in assessments need to maintained.Pls guide any case laws.
consistency in income tax assessments
28 Sep 2017 
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Consistency in tax assessments: prior acceptance of interest deductions supports continued allowance when facts remain unchanged.
Consistency in income tax assessments requires identical treatment where facts are unchanged: earlier allowance of interest supports continued allowance unless the assessing officer points to material change. The taxpayer must rebut allegations that loan proceeds were not utilised for business by producing documents and earlier assessment records; absence of new facts weakens an ad hoc disallowance and is a matter for appeal. (AI Summary)
Consistency in income tax assessments requires identical treatment where facts are unchanged: earlier allowance of interest supports continued allowance unless the assessing officer points to material change. The taxpayer must rebut allegations that loan proceeds were not utilised for business by producing documents and earlier assessment records; absence of new facts weakens an ad hoc disallowance and is a matter for appeal. (AI Summary)