Binding precedent controls disputed tax issue, leading to success for the Revenue.

Where a controversy is squarely covered by an earlier binding decision, the Court will follow that precedent and dispose of the matter accordingly. The appeal was allowed because the issue was already decided in favour of the Department in the earlier ruling, and the assessee's claim could not survive against that binding authority. The operative principle is that precedent governs where the legal issue is directly covered, and the Revenue succeeded on that basis.

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Issues: Whether the appeal was liable to succeed on the basis that the issue stood covered by an earlier decision in favour of the Department.

Analysis: The matter was treated as squarely covered by the earlier decision relied upon by the Court, and that precedent was applied to the controversy before it.

Conclusion: The issue was decided in favour of the Department, and the appeal was allowed.

Final Conclusion: The assessee's claim did not survive in view of the binding earlier decision, and the Revenue succeeded in the appeal.

Ratio Decidendi: Where the controversy is squarely covered by an earlier binding decision, the Court will follow that precedent and dispose of the appeal accordingly.

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