Binding precedent in refund disputes: quasi-judicial authorities cannot rely on overruled law, and interim deposit was ordered.

Quasi-judicial authorities must follow binding court decisions and cannot reject a refund claim by relying on an overruled ruling. In this matter, the Court noted that the Assistant Collector had declined the assessee's refund claim on the basis of no longer good law, and therefore confined the petition at the admission stage while considering interim protection. Rule was issued, and the respondents were directed to deposit the disputed refund sums with the Prothonotary and Senior Master within one week, with the petitioners allowed to withdraw the amount without furnishing security.

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Issues: Whether the petition, at the stage of admission, should be finally disposed of and whether interim relief in the nature of deposit of the disputed refund amount should be granted.

Analysis: The Court recorded that the Assistant Collector had rejected the refund claim by relying on an overruled decision, and emphasised that quasi-judicial authorities are bound by the decisions of the Court and cannot rely on a no longer good law to reject an assessee's claim. Since the Department insisted that the petition should only be admitted and kept pending, the Court confined itself to admission and considered the request for interim protection.

Outcome: Rule issued. The respondents were directed to deposit the specified sums with the Prothonotary and Senior Master within one week, and the petitioners were permitted to withdraw the amount without furnishing security.

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