is there any case law in relation example mentioned below : - Example : - Assessment of ABC company was completed for A Y 2015-16 in which addition was mate u/s. 14A or other issue , which was deleted by ITAT and against which department has not filled appeal till date.
and now assessment for A Y 2016-17 is under going and same issue was raised by Ld. AO, However we have argued that same issue was raised in A Y 2015-16 and deleted by ITAT but AO is not considering the same and asking for addition . .
My question is that why to follow the same procedure if same issue is closed once hence i am asking that is there any case law in favor of this position so that procedural aspect will reduce our tax and compliance burden. .
CAclubindia
