Held that  the assessee had been consistently filing its return of income in India and had been availing of the treaty benefits with respect to such income for all such years without being denied the treaty benefits in any of those years. The Dispute Resolution Panel could not have sustained the draft addition without assigning any reasons for drifting from the rule of consistency. It could, hence, be sufficiently established that the transaction, which the Assessing Officer had alleged to be out of tax evasion and treaty shopping, was, in fact, a long-term investment decision by an entity, which had sufficient managerial and operational structure to run an entity based in Singapore. Denial of exemption is not justified. (AY. 2017-18)