Binding precedent in the assessee's own case governed deduction and section 80HH issues across multiple tax claims.

Prior decisions in the assessee's own case controlled four income-tax questions, and the Madras HC followed that earlier view without fresh merits review. Interest paid under section 220(2) was held not allowable as a deduction, proportionate cash compensatory support on exports was denied relief under section 80HH, gratuity paid to directors was treated as includible in remuneration for section 40C computation, and interest income plus sale proceeds of processed waste attributable to the new industrial undertaking were denied section 80HH relief. The governing principle was that a question already covered by a binding decision in the assessee's own case must be applied again unless distinguished.

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Issues: (i) Whether interest paid under section 220(2) of the Income-tax Act, 1961 is an allowable deduction against the company's profits; (ii) whether the proportionate cash compensatory support on exports attributable to the new industrial undertaking qualifies for relief under section 80HH of the Income-tax Act, 1961; (iii) whether gratuity paid to directors is includible in remuneration for computing expenditure under section 40C of the Income-tax Act, 1961; and (iv) whether interest income and sale proceeds of processed waste attributable to the new industrial undertaking qualify for relief under section 80HH of the Income-tax Act, 1961.

Issue (i): Whether interest paid under section 220(2) of the Income-tax Act, 1961 is an allowable deduction against the company's profits.

Analysis: The issue was treated as covered by the decision in the assessee's own case, and the prior ruling was followed without fresh examination of the merits.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Issue (ii): Whether the proportionate cash compensatory support on exports attributable to the new industrial undertaking qualifies for relief under section 80HH of the Income-tax Act, 1961.

Analysis: The question was stated to be governed by an earlier decision in the assessee's own case, which had already negatived the claim for relief.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Issue (iii): Whether gratuity paid to directors is includible in remuneration for computing expenditure under section 40C of the Income-tax Act, 1961.

Analysis: The matter was held to be covered by an earlier decision in the assessee's own case, and the prior view was applied in the present reference.

Conclusion: The issue was decided in favour of the assessee and against the Revenue.

Issue (iv): Whether interest income and sale proceeds of processed waste attributable to the new industrial undertaking qualify for relief under section 80HH of the Income-tax Act, 1961.

Analysis: The question was found to be covered by an earlier judgment in the assessee's own case, and that ruling was followed.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Final Conclusion: The references were answered by applying earlier decisions in the assessee's own case, with three issues going against the assessee and one issue succeeding.

Ratio Decidendi: Where a question is already covered by a binding decision in the assessee's own case, the same view is to be followed in the subsequent reference unless distinguished.

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