As per case facts, a firm with two PANs had its banking transactions under PAN-1 for AY 2019-20 already assessed by an ITO, who found the income disclosed under PAN-2 ... and assessed it as NIL. Later, a DCIT initiated fresh assessment proceedings for the same transactions and year, despite the firm explaining prior assessment. The firm challenged this, citing double taxation. The question arose whether a DCIT could re-assess income for the same assessment year and transactions that had already been finalised by an ITO. Finally, the High Court ruled that the firm cannot be assessed twice for the same matter. It applied the principle of finality of adjudication, stating that the ITO's order had attained finality, and quashed the DCIT's subsequent proceedings as invalid and self-conflicting.