Binding precedent on the same tax issue required the later appeal to follow Liberty India and favoured the Revenue.

A later appeal on the same tax issue was governed by the Supreme Court's earlier ruling in Liberty India v. CIT. Because the point in dispute was already conclusively settled by binding precedent, no separate basis existed for a different view in the present matter. The Court therefore applied the earlier decision, allowed the Department's appeals, and set aside the relief granted to the assessee. The operative principle is that once the Court has finally decided an issue, that ruling must govern subsequent appeals involving the same question.

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Issues: Whether the Department's appeals were liable to be allowed in view of the earlier decision of the Court governing the same issue.

Analysis: The issue raised in the appeals was treated as squarely covered by the Court's earlier ruling in Liberty India v. CIT, leaving no separate basis for a different view in the present matter.

Conclusion: The appeals were allowed, resulting in a decision in favour of the Revenue.

Final Conclusion: The Department succeeded and the impugned relief in favour of the assessee was set aside in consequence of the binding earlier precedent.

Ratio Decidendi: Where the issue is already concluded by a binding decision of the Court, the same view must govern the later appeal and the Department's challenge may be allowed accordingly.

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