Courts Emphasize Consistency in Subsidy Classification for Tax; Res Judicata Principles Don't Apply, But Facts Must Remain Stable.

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....Nature of subsidy received - Capital or revenue receipt - Though the principles of res judicata doesn’t apply in the income tax proceedings, however, it has also been laid down by the Courts that unless there are changes in the facts and circumstances of the case, past consistent position so adopted should not be disturbed....