The AO held that interest on money borrowed by firm and advanced by it in turn to its partners hence made the disallowance. CIT(A) deleted the addition holding that it was a notional income and debit balance in partner’s current account had been carried forward from past several years but there were no additions made on said count in those years.  Tribunal held that in view of fact that debit balance in one of partner’s current account was appearing for last several years and in none of earlier years any such hypothetical income had been subjected to tax in hands of assessee, following principle of consistency, there was no justification of AO in imputing interest income on debit balance of said partner. Order of CIT(A) is affirmed. (AY. 2011-12, 2012-13)