https://www.taxtmi.com/caselaws?id=773417 The ITAT Delhi dismissed the assessee's appeal regarding royalty expenditure classification. The assessee, a manufacturer of oil seals for automobiles, argued for consistency in treatment and claimed res judicata principles. The Tribunal held that res judicata does not apply to income tax cases and found no merit in the consistency argument, as no categorical finding from previous assessment orders was produced. The Tribunal emphasized that cases must be appreciated in totality rather than relying on selective quotations from decisions taken out of context. en-us Mon, 28 Apr 2025 00:00:00 +0530 Mon, 23 Jun 2025 08:42:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773417 The ITAT Delhi dismissed the assessee's appeal regarding royalty expenditure classification. The assessee, a manufacturer of oil seals for automobiles, argued for consistency in treatment and claimed res judicata principles. The Tribunal held that res judicata does not apply to income tax cases and found no merit in the consistency argument, as no categorical finding from previous assessment orders was produced. The Tribunal emphasized that cases must be appreciated in totality rather than relying on selective quotations from decisions taken out of context. Case-Laws Income Tax Mon, 28 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773417