Court held that AO examined the claim in original assessment proceedings. Similar claim was allowed in earlier assessment years. Rule of consistency is applied and revision is held to be not valid. (AY. 1999-2000 to 2001-02)
CIT v. Kohinoor Foods Ltd. (2019) 414 ITR 249 / 180 DTR 41(Delhi)(HC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue–AO examined the claim in original assessment proceedings–Rule of consistency is applied–Revision is held to be not valid. [S.143(3), 80HHC]