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1999 (11) TMI 111 - ITAT DELHI-EExtract: .......e true that the doctrine of res judicata or the rule of estoppel is not applicable to income-tax proceedings, yet the rule of consistency does apply to such proceedings. On the facts and in the circumstances of the case we do not find any infirmity in the order of the learned CIT(A) and hence we affirm it. 7. In the result, the appeal is dismissed.
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