Consistency Over Technicalities – ITAT Allows Actuarial Pension Provision & Rejects Mechanical Disallowances

State Bank of India Vs ACIT (ITAT Mumbai) Consistency Over Technicalities – ITAT Allows Actuarial Pension Provision & Rejects Mechanical Disallowances Mumbai ITAT dealt with extensive cross-appeals involving multiple disallowances and claims of a banking entity, while laying down important principles on consistency, allowability of claims, and interpretation of tax provisions. The Tribunal clarified that: Though res judicata does not strictly apply, the principle of consistency must be followed where facts and law remain unchanged Revenue cannot deviate from earlier accepted positio...