Year-to-year income-tax status can be re-examined; earlier HUF finding does not bar later individual assessment.

Later-year income-tax status is not controlled by an earlier assessment-year finding, and a finding on one year does not operate as res judicata for subsequent years. A HUF claim can succeed only when partition or family status is conclusively established under the applicable statutory scheme; otherwise the assessee may be assessed as an individual. The text treats section 171 of the 1961 Act and section 25A of the 1922 Act as reflecting a principle of comity for status recognition, not a general bar on year-to-year re-examination.

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Issues: Whether the assessee was entitled to be assessed as a Hindu Undivided Family instead of an individual for the relevant assessment years, and whether the earlier partition-related order prevented the Revenue from treating him as an individual in later years.

Analysis: The return history and earlier assessment orders showed no consistent treatment of the assessee's status, and the finding in one assessment year did not operate as res judicata in later years. A final order recognising partition under the statutory scheme has a conclusive effect, but absent a legally effective basis to disturb the later individual assessments, the assessee could not insist on HUF status for the years in question. The statutory principle reflected in section 171 of the 1961 Act, read with the corresponding section 25A of the 1922 Act, was treated as embodying a principle of comity rather than a general bar on re-examination of status from year to year.

Conclusion: The assessee was not entitled to HUF status for the relevant years, and the Tribunal was right in treating him as an individual.

Ratio Decidendi: An income-tax assessment for a later year is not bound by an earlier year's status finding, and a HUF claim can prevail only where the statutory consequences of partition or family status are conclusively established under the applicable provision.

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