Finality of refusal to prosecute appeal bars revival despite later recall of the dispute mechanism.

Revenue could not revive an income-tax appeal once the Committee of Disputes had refused permission and that refusal had been accepted. The later recall of the Committee of Disputes mechanism did not invalidate the earlier rejection or reopen a matter already decided with finality. The Delhi HC therefore treated the prior denial as binding and refused to permit resurrection of the appeal, leaving the Revenue without entitlement to proceed.

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Issues: Whether the Revenue could revive the appeal after the Committee of Disputes had declined permission to pursue it and the Supreme Court had later recalled the Committee of Disputes mechanism.

Analysis: The Revenue had sought permission to prosecute the appeal under Section 260A of the Income-tax Act, 1961, but the Committee of Disputes declined approval and the Revenue accepted that decision. The later recall of the Committee of Disputes mechanism did not render the earlier refusal a nullity or reopen matters already considered and decided. The judgment held that the recall could not be used to resurrect appeals where permission had been specifically denied and the decision had attained finality.

Conclusion: The Revenue was not entitled to revive the appeal; the application was rejected.

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