Binding precedent on section 254(2A) provisos bars a substantial-question-of-law challenge in revenue appeal.

An identical challenge under section 260A concerning the second and third provisos to section 254(2A) was treated as already settled by the same High Court, which had previously held that the issue does not raise a substantial question of law. Applying that binding precedent, the Court answered the issue against the Revenue and found no basis for interference. The appeal was therefore dismissed because the identical legal question had already been ined against the Revenue.

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Issues: Whether the second and third provisos to section 254(2A) of the Income-tax Act, 1961 gave rise to a substantial question of law in a revenue appeal under section 260A.

Analysis: The issue was treated as concluded by an earlier decision of the same Court holding that the identical question did not amount to a substantial question of law.

Conclusion: The question was answered against the Revenue and the appeal did not merit interference.

Final Conclusion: The appeal was dismissed in view of binding precedent on the identical issue.

Ratio Decidendi: An identical challenge under section 260A does not survive where the Court has already held that the question arising from section 254(2A) is not a substantial question of law.

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