For rejecting the view taken in earlier assessment years, there must be a change in the fact situation or a material change in law

ACIT Vs. Pawan Hans Helicopters Ltd. (ITAT Delhi)- Hon’ble Delhi High Court in A.R.J. Security Printers’ case [2003] 264 ITR 276 and CIT Vs. Neo Poly Pack P. Ltd. [2000] 245 ITR 492 (Delhi ), held that even when the doctrine of res judicata does not apply to income-tax proceedings, where an issue has been decided consistently in a particular manner for earlier assessment years, the same view should prevail even during the subsequent years unless there is a material change in the facts. The law is, therefore, fairly well se

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