Separate assessment years must be decided on their own merits; an admission in another year is not conclusive.

An appellate authority cannot dismiss an income-tax appeal in limine by treating an alleged admission from another assessment year as conclusive. Each assessment year is a separate unit of assessment, and a statement or admission made in a different proceeding does not bind the assessee so as to replace merits-based adjudication. The appeal arising from penalty under section 271(1)(a) for delay in filing the return had to be examined independently on the facts of the relevant year. The summary dismissal was therefore unjustified, and the matter was restored for fresh consideration on merits in accordance with law.

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Issues: Whether the appellate authority could dismiss the assessee's appeal in limine by relying on an alleged admission made in another assessment year, and whether the appeal had to be examined on merits.

Analysis: The return for the relevant year was due under section 139(1) of the Income-tax Act, 1961 and penalty had been levied under section 271(1)(a) for delay. The appellate authority declined to examine the merits and treated the position in a different assessment year as conclusive. Each assessment year is a separate unit of assessment and cannot be mixed up with another year. An admission, even if made in another proceeding, is not conclusive against the assessee and does not relieve the appellate authority of the duty to decide the appeal on merits.

Conclusion: The summary dismissal of the appeal was unjustified; the order was set aside and the matter was restored for fresh on merits in accordance with law.

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