Earlier year’s appellate decision could not be applied if facts of current year has changed

Brief of the case: ITAT Mumbai held in Punjab & Sind Dairy Products Pvt Ltd Vs Dy. CIT that in the case of assessee itself in earlier year, ITAT had rejected the books of accounts on the basis that assessee failed to produce books of accounts as demanded by ITAT. But in the year under consideration as assessee had presented all the books of accounts and documents as required by AO and CIT(A) so the same could not be rejected just by applying the assessee’s case of earlier year because in that case of earlier year facts and materials were different, in that case assessee failed to produce...