PR. COMMISSIONER OF INCOME TAX-2, DELHI vs. M/S BHISHANSAROOP RAM
ITA/953/2019HC Delhi28 Mar 2024
Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE PURUSHAINDRA KUMAR KAURAV
…ue enough that subsequent light or ingenuity might suggest some traverse which had not been taken.‘ (Hoystead case [1926 AC 155 : 1925 All ER Rep 56 (PC)] , AC pp. 165-66)‖ 26. Reference was also made to Parashuram Pottery Works Co. Ltd. v. ITO [(1977) 1 SCC 408 : 1977 SCC (Tax) 179 : (1977) 106 ITR 1] and then it was held: (Radhasoami Satsang case [(1992) 1 SCC 659 : (1992) 193 ITR 321] , SCC p. 666, paras 16-17) ―16. We are aware of the fact that strictly speaking res judicata does not apply to income tax proceedings. Again, each assessment year being a unit, what is decided in one year may not app…