Assessee-firm had three partners. One of the partner had debit balance . On borrowed money the assessee was paying interest at the rate of 12 percent .  The Assessing Officer disallowed the interest paid on borrowed  amount . CIT (A) deleted the addition .  On appeal by revenue the Tribunal held 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 Assessing Officer in imputing interest income on debit balance of said partner and subjecting same to tax in hands of assessee in assessment year in question .  (AY. 2011-12 )