https://www.taxtmi.com/caselaws?id=764497 The ITAT Bangalore upheld the CIT(A)'s decision allowing exemption under Section 11 to the assessee, rejecting the Revenue's attempt to deny the benefit by disregarding payments made to specified persons under Section 13(1)(c). The tribunal applied the Principle of Consistency, noting that Revenue had allowed similar exemptions in the assessee's earlier assessment years (2014-15, 2015-16, 2016-17) under identical circumstances. The tribunal held that while res judicata doesn't apply to tax proceedings, Revenue cannot deviate from prior decisions without demonstrating changed factual circumstances. Since no material differences existed between current and earlier years, and the Departmental Representative failed to establish any variation in facts, the Revenue's divergent position was rejected. The appeal was decided against Revenue. en-us Tue, 03 Dec 2024 00:00:00 +0530 Fri, 10 Jan 2025 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764497 The ITAT Bangalore upheld the CIT(A)'s decision allowing exemption under Section 11 to the assessee, rejecting the Revenue's attempt to deny the benefit by disregarding payments made to specified persons under Section 13(1)(c). The tribunal applied the Principle of Consistency, noting that Revenue had allowed similar exemptions in the assessee's earlier assessment years (2014-15, 2015-16, 2016-17) under identical circumstances. The tribunal held that while res judicata doesn't apply to tax proceedings, Revenue cannot deviate from prior decisions without demonstrating changed factual circumstances. Since no material differences existed between current and earlier years, and the Departmental Representative failed to establish any variation in facts, the Revenue's divergent position was rejected. The appeal was decided against Revenue. Case-Laws Income Tax Tue, 03 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764497