Binding precedent supports section 12-A registration for a development authority; Revenue's challenge to exemption eligibility failed.

Binding precedent on similarly placed development authorities was applied to hold that the assessee authority satisfied the criteria for registration under section 12-A of the Income-tax Act, 1961. The HC found no basis to interfere with the Tribunal's reliance on its earlier decisions, which had already been upheld, and rejected the Revenue's challenge to the authority's status as a local authority and its eligibility for exemption. The questions of law were answered against the Revenue and in favour of the assessee, and the appeal was dismissed.

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Issues: Whether the assessee development authority was entitled to registration under section 12-A of the Income-tax Act, 1961, and whether the questions raised by the Revenue regarding its status as a local authority and its eligibility for exemption warranted interference.

Analysis: The Tribunal had granted registration by relying on its earlier decisions concerning similarly placed development authorities. Those decisions had already been upheld by the High Court. In view of that binding precedent, the respondent-authority was held to have satisfied the criteria for registration under section 12-A. The Court found no reason to take a different view on the questions framed by the Revenue.

Conclusion: The questions of law were answered against the Revenue and in favour of the assessee. The appeal was dismissed.

Ratio Decidendi: Where the issue is covered by binding precedent and the assessee satisfies the criteria for registration under section 12-A, the Revenue's challenge to such registration cannot succeed.

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