Finality of earlier tax rulings prevents a party from re-litigating their correctness in a later assessee's case after acquiescence.

A party cannot accept an earlier High Court ruling in one matter and later contest its correctness in another case involving a different assessee without showing a proper challenge to that ruling. Here, the Revenue failed to demonstrate that it had pursued, or even adequately explained, any challenge against the earlier judgment. The Court therefore declined to examine the correctness of that decision and did not entertain the Revenue's challenge in the present appeal.

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Issues: Whether the Revenue could challenge the correctness of an earlier High Court judgment in the present assessee's case after not having effectively disputed that judgment in the earlier matter.

Analysis: The appeal arose from an order that followed an earlier High Court decision. The Revenue was unable to show that it had pursued, or even adequately explained the fate of, any challenge against that earlier judgment. The Court held that a party cannot accept a decision in one case and, without just cause, seek to contest its correctness in another case involving another assessee. In such circumstances, the Court declined to examine the correctness of the earlier High Court decision.

Conclusion: The Revenue's challenge was not entertained, and the appeal was dismissed.

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