M.M. Kumar, C J.;— 1. The instant appeal by the Revenue filed under Section 260-A of the Income Tax Act, 1961 (for brevity the Act) is directed against order dated 25.09.2012 passed by the Income Tax Appellate Tribunal, Amritsaf Bench in ITA no. 304(ASR)/2010 in respect of assessment year 2006-07. The Revenue has claimed that the following substantive question of law whether the Tribunal is right in law and in facts in deleting the additions made under Section 40 (a) (ia) on lease rent paid, on expenses and on account of interest paid. 2. The assessee-respondent is a dealer of Maruti Cars. It is also engaged in repairs, service of the cars and other allied matters. It had filed original return of income for the assessment year 2006-07 on 31.11.2006 which was subsequently revised declaring an income of Rs.21,64,600/. The assessment was completed under Section 143(3) of the Act in which additions were made disallowing under Section 40 (a) (ia) rent paid on lease, on expenses and on account of interest paid. 3. On appeal, the CIT(A), Bathinda partly allowed the appeal of the assessee-respondent and deleted the addition in respect of disallowance under Section 40 (a) (ia) made on lease rent of Rs. 15,60,000/- by holding that the lease rent paid is on account of plant and machinery as per the MOU and there is no requirement under Section 194-1 to deduct tax at source on any rent for machinery. It was further held that the expenditure of Rs. 15,60,000/- has been incurred during the year and there was nothing payable. The CIT(A) followed the principle that the only expenditure which remained payable and on which tax has not been deducted and not deposited would attract application of provisions of Section 40 (a) (ia) by following the judgment of IT AT Jaipur Bench in the case of M/s Jaipur Vidyut Vitran Nigam Ltd. v. DCIT (2009) 123 TTJ 888. Likewise, disallowance under Section 40 (a) (ia) made on expenses of Rs.46,86,912/- was also deleted by the CIT(A) by placing reliance on the same judgment and the same principle. 4. Feeling aggrieved the appellant-department has approached the Tribunal and the appeal has been dismissed by confirming the order of CIT (A). The Tribunal has placed reliance on the order passed by Jaipur, Hyderabad and Vishakapatnam Benches. 4. Feeling aggrieved the appellant-department has approached the Tribunal and the appeal has been dismissed by confirming the order of CIT (A). The Tribunal has placed reliance on the order passed by Jaipur, Hyderabad and Vishakapatnam Benches. In that regard, reliance has been placed on the order of the Tribunal rendered in the case of M/s. Jaipur Vidyut Vitran Nigam Ltd v. DCIT (2009) 123 TTJ 888 and IT AT, Hyderabad Bench in the case of M/s Teja Constructions v. ACIT in ITA no. 30/HYD/2009, on the identical issue. Likewise a reference has been invited to the judgment of the Special Bench, Vishakapatnam of the Tribunal in the case of M/s Merilyn Shipping and Transports, Vishakapatnam v. Additional Commissioner of Income Tax (ITA no. 477/Viz/2008 decided on 29.03.2012). 5. At the hearing, we have asked learned counsel for the Revenue about the status of the aforesaid orders passed by various Benches of the Tribunal, in order to satisfy ourselves whether the Revenue has accepted the orders or such orders have been subject matter of challenge in appeal before the jurisdictional High Courts. There is no satisfactory answer given which, in fact, lead us to conclude that the orders of various Tribunals stand accepted by the Revenue. In such a situation the principle of consistency would be attracted as has been laid down in the cases of Radha Soami Satsang v. Commissioner of Income Tax 193 ITR 321 SC and Berger Paints India Ltd. v. Commissioner of Income Tax 253 ITR 738. Therefore, we regret our Inability to accept that any question of law much less a substantive question of law would emerge for admission of the appeal, particularly when there was hardly any loss of Revenue. Accordingly, the appeal is dismissed.