Finality of adjudication bars the revenue from re-agitating an issue already concluded against it.

Where an issue had already been conceded before the Tribunal and had attained finality after dismissal of the revenue's earlier appeal, the revenue could not reopen the same question by asserting factual differences. The principle applied was finality of adjudication: a concluded issue cannot be re-agitated on the same dispute once the earlier decision has become final. The issue was therefore answered against the revenue and in favour of the assessee.

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Issues: Whether the revenue could re-agitate an issue already concluded against it by an earlier final decision.

Analysis: The issue had already been conceded before the Tribunal as concluded by an earlier decision. That decision had attained finality upon dismissal of the revenue's appeal. In these circumstances, the revenue could not be permitted to reopen the same issue by contending that the facts were different.

Conclusion: The issue was answered against the revenue and in favour of the assessee, and the appeal was dismissed.

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