Larger-Bench precedent prevails over a conflicting smaller-Bench view on rice sales tax computation and invalidates reassessments.

A larger-Bench interpretation prevails where judicial views conflict, so a contrary smaller-Bench ruling cannot displace an earlier binding three-member Bench decision on computation of the sales tax component in rice sales under Section 8A(1) of the Central Sales Tax Act, 1956 and the corresponding State rule. Because the later two-member Bench view was rendered without the earlier larger-Bench ruling being placed before it, it could not be treated as good law. Administrative circulars and reassessments founded on that contrary view were therefore invalid, and the reassessments were set aside.

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Issues: Whether the view taken by the two-member Bench on determination of the tax component on sale of rice could prevail over the earlier three-member Bench view, and whether the circular and assessments based on the two-member Bench decision were valid.

Analysis: The controversy concerned computation of sales tax component on the sale price of rice under Section 8A(1) of the Central Sales Tax Act, 1956 and the corresponding rule under the Andhra Pradesh General Sales Tax Rules, 1957. A three-member Bench had earlier settled the question, and the settled position was binding unless displaced by a still larger Bench. The later two-member Bench took a contrary view without the earlier larger Bench decision being placed before it, which created confusion and led to administrative circulars and reassessments. Since the larger Bench view remained unshaken, the contrary smaller Bench view could not be treated as good law.

Conclusion: The two-member Bench decision was held not to be good law, the circular and assessments based on it were invalid, and the reassessments were set aside.

Final Conclusion: The writ petitions succeeded because the binding larger-Bench interpretation governed the computation of tax on rice and the impugned departmental action based on the contrary smaller-Bench view could not stand.

Ratio Decidendi: Where two judicial views conflict, the view of the larger Bench prevails and a contrary smaller-Bench decision cannot override an earlier binding larger-Bench ruling.

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