Res judicata barred a repeat valuation dispute for the same period, leading to rejection of the Revenue's appeal.

The valuation dispute for the same period had already been decided in favour of the assessee in an earlier order, and the Revenue had accepted that decision without challenge. Because the present notice covered the same adjudicated period and issue, the Commissioner was justified in following the earlier orders and applying res judicata. No basis was found to depart from the prior determination, so the Revenue's appeal was rejected.

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Issues: Whether the Revenue's appeal against the Commissioner's order was liable to be rejected in view of the earlier adjudication on the same valuation dispute for the same period.

Analysis: The earlier order of the Commissioner on the disputed issue had already decided the matter in favour of the assessee and had been accepted by the Revenue without challenge. The period covered by the present notice had also been adjudicated earlier. In these circumstances, the Commissioner was justified in following the earlier orders and applying the principle of res judicata. No reason was found to take a different view.

Conclusion: The Revenue's appeal was rejected.

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