Prior Tribunal order in assessee's own case governed identical years, leading to allowance of the appeals and infructuous stay applications.

ITAT Delhi held that the assessee's appeals for the relevant assessment years were covered by its earlier order in the assessee's own case on identical facts, so the same reasoning was followed for the years in question and the appeals were allowed. The Tribunal applied the principle that where the material issue has already been decided in the assessee's own case, that view may govern subsequent years when the facts remain the same. The stay applications consequently became infructuous.

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Issues: Whether the assessee's appeals for the relevant assessment years were liable to be allowed as the controversy stood covered by the Tribunal's earlier order in the assessee's own case.

Analysis: The issues raised in the appeals were treated as squarely covered by the Tribunal's order in the assessee's own case for the earlier assessment year. The same reasoning was followed for the years under consideration.

Conclusion: The assessee's appeals were allowed.

Final Conclusion: The dispute was decided in favour of the assessee on the basis of the Tribunal's earlier view in its own case, and the stay applications became infructuous.

Ratio Decidendi: Where the material issue is already covered by an earlier order in the assessee's own case, the same view may be followed for subsequent years on identical facts.

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