The MP High Court in Luchhiram Puranmal v. CIT (119TAX1) held that the assessment in earlier years does not bind the assessing authority and the assessing authority can on the material placed before it, take a different view in the subsequent years although the findings in the earlier years on the same subject matter can be considered as cogent evidence. In distinguishing the concept of judicial discipline the High Court clarified that though it is true that the orders of the higher authorities should be followed unreservedly by the subordinate authorities but the authorities at same level meaning assessing officer to assessing officer, Commissioner (A) to another Commissioner (A) can differ from year to year in which case the doctrine of Res judicata has no application among them.
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