Royalty attribution challenge remains open in later years despite earlier appeal withdrawal.

An earlier withdrawal of appeals did not bar the assessee from contesting the attribution of 25% royalty in later assessment years. The appellate authority was required to consider the later-year objections on merits and could not treat the prior withdrawal as determinative of those subsequent proceedings. The right to raise the same or connected challenge therefore remained open in the later appeals.

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Issues: Whether the assessee's earlier withdrawal of the appeals precluded it from challenging the attribution of 25% royalty in later assessment years, and whether the appellate authority was bound by the earlier withdrawal while considering the later appeals.

Analysis: The earlier order recording withdrawal of the appeals did not foreclose the assessee from raising the same or connected objections in later years. The right to question the attribution of 25% royalty remained open in the later appeal proceedings, and the appellate authority was required to examine the assessee's contentions on merits instead of treating the earlier withdrawal as determinative.

Conclusion: The assessee was permitted to agitate the issue on merits in the later years, unhindered by the earlier withdrawal.

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