HC explains difference between Res Judicata and Consistency Principle

PCIT Vs. Quest Investment Advisors Pvt. Ltd (Bombay High Court)

The decisions cited have uniformly held that res judicata does not apply in matters pertaining to tax for different assessment years because res judicata applies to debar courts from entertaining issues on the same cause of action whereas the cause of action for each assessment year is distinct. The courts will generally adopt an earlier pronouncement of the law or a conclusion of fact unless there is a new ground urged or a material change in the f

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