DCIT, ROURKELA vs. SHRI PRASHANT KUMAR AHLUWALIA, SUNDERGARH
In the result, appeal of the department is allowed and that of the
ITA 63/CTK/2015[2011-12]Status: DisposedITAT Cuttack17 Sept 2020AY 2011-12
Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahuassessment Year : 2011-2012
For Appellant: Shri Sunil Mishra, AdvocateFor Respondent: Shri M.K.Gautam, CIT, DR
Section 132(1)Section 139(1)Section 143(2)Section 144Section 145(3)Section 14ASection 153A
…ll settled that "each assessment year is a separate self-contained period and the doctrine of res judicata is not applicable to income tax proceedings". The ratio of the Hon'ble Supreme Court in the case of Instalment Supply (P) Ltd. v. Union of India, (1962) 2 SCR 644, 658 was cited which held that "it was well settled that in the matter of taxation there is no question of res judicata because each year's assessment is final only for that year and does not govern later years". The ratio of the Supreme Court in the case of New Jehangir Vakil Mills Co. Ltd. vs CIT, (1963) 49 ITR 137 was also cited which observed t…