‘No Change in Facts from AY 2013-14 TDS Ruling’: ITAT Relies on Consistency Principle to Dismiss Revenue’s Appeal

In a significant TDS case, the ITAT dismissed the revenue department's appeal by applying the consistency principle, noting identical facts since AY 2013-14. The tribunal emphasized that tax authorities cannot arbitrarily change positions on the same set of facts across assessment years. This decision reinforces the principle of certainty in tax administration and protects taxpayers from inconsistent treatment while allowing genuine case-by-case distinctions where justified.