The Mumbai High Court in CIT vs. State Bank Of India has held that uniformity in treatment is the basis premise of rule of law. The Dept cannot arbitrarily pick and choose which orders of the ITAT should be challenged in the High Court. If ITAT has followed an order which is not challenged by the Dept then an affidavit must be filed explaining the distinguishing features which warrants the different view - [2015-ITRV-HC-MUM-117]