(2)Where, in pursuance of the orders, instructions or directions issued under sub-section (1), an income-tax authority has not filed any appeal on any issue in the case of an assessee for any tax year, it shall not preclude such authority from filing an appeal on the same issue in the case of—(a)the same assessee for any other tax year; or(b)any other assessee for the same or any other tax year.
