Assessee had taken loan from banks at interest at rate of 14 to 16 per cent per annum. It advanced loan to its wholly owned subsidiary company at rate of 6 per cent only.  When assessee was asked to explain why commercial interest rate was charged from subsidiary company, assessee stated that since subsidiary company was incurring losses, management decided to charge lesser rate of interest.  Assessing Officer made the addition  being shortage in interest recovered from subsidiary. Tribunal held that   loan was given in earlier financial year and assessee had sufficient own funds to give loan and further no disallowance was made in earlier assessment year. Disallowance was deleted by following the rule   of consistency  as there was no change in law and facts. High Court affirmed the order of the Tribunal. (AY. 2010-11)