Tax Officer's Conflicting Stance on Deduction Claims Violates Consistency Rule u/s 147 & 80IB of Income Tax Act.

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....Reopening of assessment u/s 147 - assessee has claimed deduction u/s 80IB without allowing interest on capital and remuneration to the partners - the same officer has took two contrary view in respect of the same assessee on the similar issue, which is not permissible under the provisions of the income tax Act. The revenue authorities are requires to adhere the principles of consistency while considering the similar issues, when there is no variations in the facts in earlier or subsequent year. - AT....