https://www.taxtmi.com/caselaws?id=206620 Non-filing of an appeal in one tax matter does not, by itself, prevent the Revenue from taking a different stand in another case, because consistency cannot override statute, estoppel does not operate across different assessments in the manner claimed, and a contrary view may still be open where just cause exists or the earlier view is distinguishable. A circular issued under Section 37B may promote uniformity, but it cannot compel assessing authorities to ignore a prior tribunal ruling or replace their independent quasi-judicial judgment. The assessing authority must consider the tribunal decision and treat the circular only as guidance; the impugned circular portion directing otherwise was invalidated. en-us Fri, 30 Sep 2011 00:00:00 +0530 Mon, 20 Feb 2012 11:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206620 Non-filing of an appeal in one tax matter does not, by itself, prevent the Revenue from taking a different stand in another case, because consistency cannot override statute, estoppel does not operate across different assessments in the manner claimed, and a contrary view may still be open where just cause exists or the earlier view is distinguishable. A circular issued under Section 37B may promote uniformity, but it cannot compel assessing authorities to ignore a prior tribunal ruling or replace their independent quasi-judicial judgment. The assessing authority must consider the tribunal decision and treat the circular only as guidance; the impugned circular portion directing otherwise was invalidated. Case-Laws Central Excise Fri, 30 Sep 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206620