Learned counsel for the appellant submits that the Tribunal has erred in proceedings on the basis of the said decision of the High Court, since in taxation matters, concept ofres judicatadoes not apply and each assessment year has to be treated separately and the issues arising in each year have to be considered and examined separately.He submits that the issue-whether RRIL constitutes PE of the appellant in the light of that decision, needs examination afresh. His further submission is that on the same set of facts, the liaison office of RRIL has been held to be the PE of the appellant, as well as that of RRIL, which is not possible.