Loans and Interest Payment Accepted in Past Years Cannot Be Disputed Without Fresh Grounds: ITAT Deletes Additions

ITAT deleted additions related to loans and interest payments that were accepted in past years, ruling that revenue cannot reopen settled matters without fresh evidence. The tribunal emphasized the importance of consistency in tax assessments and barred fishing expeditions into previously examined transactions. The decision protects taxpayers from arbitrary reassessment of long-standing arrangements unless the department demonstrates new incriminating material