Res Judicata Doesn't Apply to Tax: Each Year Stands Alone, But Consistency Matters if Unchallenged Over Time.

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....Principle of res-judicata or estoppal is not applicable in the income tax proceedings, as each assessment year is an independent assessment year. - But fact remains that where a fundamental aspect permeating through the different assessment years has been found as a fact one way or the other and parties have allowed that position to be sustained by not challenging the order, it would not be at all appropriate to allow the position to be changed in a subsequent years - HC....