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    <title>2026 (8) TMI 176 - ITAT RAIPUR</title>
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    <description>Consistency in tax assessment required acceptance of the school as part of the registered educational society where the Revenue had accepted that status in an earlier year and established no contrary evidence, material factual distinction, or changed circumstances. Although each assessment year is separate and res judicata does not strictly apply to taxation, the authorities had not verified whether the school&#039;s income was already included in the society&#039;s accounts. The separate assessment of the school and the related addition could therefore not be sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796303</link>
      <description>Consistency in tax assessment required acceptance of the school as part of the registered educational society where the Revenue had accepted that status in an earlier year and established no contrary evidence, material factual distinction, or changed circumstances. Although each assessment year is separate and res judicata does not strictly apply to taxation, the authorities had not verified whether the school&#039;s income was already included in the society&#039;s accounts. The separate assessment of the school and the related addition could therefore not be sustained.</description>
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