Finality of unchallenged Tribunal rulings bars the Revenue from taking a contrary stand on the same issue in later appeals.

Where earlier Tribunal decisions on the same issue had attained finality because the Revenue did not appeal them, the Revenue was precluded from taking a contrary position in later proceedings. The Court applied the principle that an identical question, once finally decided and left unchallenged, binds the Revenue in subsequent cases. On that basis, the contrary stand in the present appeals was not permitted and the appeals were liable to be dismissed.

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Issues: Whether the Revenue, having not challenged earlier Tribunal decisions on the same question, could be permitted to take a contrary stand in the present appeals.

Analysis: The earlier Tribunal decisions relied upon by the assessee had attained finality, as no appeal had been filed against them. The issue raised in the present appeals was the same or similar. In such circumstances, the Revenue was barred from disputing the same question in later proceedings.

Conclusion: The Revenue could not take a contrary stand, and the appeals were liable to be dismissed.

Final Conclusion: The judgment applies the rule that final, unchallenged decisions on an identical question bind the Revenue in subsequent proceedings, resulting in dismissal of the appeals.

Ratio Decidendi: Where the Revenue does not challenge an earlier decision on an identical issue and that decision attains finality, it is precluded from advancing a contrary position in later proceedings on the same question.

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