Powerloom Developement & Export ... vs Ito (E) 2(2), Mumbai on 24 July, 2018
iii. Appellant contended that it has been granted exemption u/s. 11 in all
earlier years and since there is not change in circumstances in the current
year, exemption u/s. 11 should have been alloed by the assessing officer.
In this regard it is mentioned that the principle of resjudicata does not
apply to income tax proceedings. Thus leal position is settled and clear
that „Rule of Consistency‟/ re-judicata is not applicable and each
M/s Powerloom Development & Export Promotion Council Vs. ITO(E)-2(2) - A.Y. 2012-13 5
ITA No. 1185/Mum/2017
assessment year is a separate proceedings, as also affirmed in the
decision of the Apex court in Bharat Sanchar Nigam Ltd. Vs. Union of India
(S.C) 282 ITR.