Res Judicata Not Applicable: Previous Assessment Lacked Discussion, Mere Acceptance of Assessee's Contention Not Conclusive.

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....Doctrine of res judicata - The previous year’s assessment order in fact did not lead any discussion on this aspect and appear to have merely accepted the assessee’s contention. Those cannot by any stretch of imagination be conclusive. At any rate in such cases, one cannot apply the principle of res judicata or estoppel. - HC....