INCOME TAX OFFICER, WARD-3(4), GUWAHATI vs. M/S. S.R.K.M. STEELS (P) LTD, GUWAHATI
In the result, the appeal of the Revenue is dismissed
ITA 274/GTY/2018[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16
Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm Income Tax Officer, Ward 3(4) M/S S.R.K.M Steels (P) Ltd. Room No.707, 7Th Floor, Aayakar M/S Srkm Steels (P) Ltd. Lokhra Bhawan Poorva, G.S. Road, Road, P.O. Sawkuchi, Guwahati- Vs. Guwahati-781005, Assam 781034, Assam (Appellant) (Respondent) Pan No. Aalcs5046E Assessee By : Shri Somnath Ghosh, Ar Revenue By : Shri Santosh Kumar Karnani, Dr Date Of Hearing: 17.11.2025 Date Of Pronouncement: 18.12.2025
For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar karnani, DR
Section 133(6)
193 ITR 321], held as under:
"..Strictly speaking, res judicatta does not apply to the income tax proceedings.
Though, each assessment year being a unit, what was decided in one year might not apply in the following, year, where a fundamental aspect permeating through different assessment years has been found as afact one way or the other and parties have