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1981 (8) TMI 96 - ITAT BOMBAY-BExtract: ....... This has been rightly done by the revenue authorities. We agree with the learned representative for the department that the principle of res judicata does not apply to the income-tax proceedings and each assessment year is separate. For the above reasons, we uphold the order of the Commissioner (Appeals). 7. In the result, the appeal is dismissed.
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