Binding prior-year decision sustained deletion of section 14A read with Rule 8D disallowance; Revenue's appeal failed.

Where the Revenue challenged deletion of a disallowance under section 14A read with Rule 8D, the High Court held that the issue was already covered against it by the assessee's own earlier year decision, which the Tribunal had correctly followed. As the settled position governed the matter, no error was found in the Tribunal's deletion of the addition. The tax appeal was dismissed and the disallowance remained deleted.

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Issues: Whether the addition deleted by the Tribunal under section 14A read with Rule 8D was liable to be restored.

Analysis: The Revenue's challenge was covered against it by the decision of the same High Court in the assessee's own case for the preceding assessment year. The Tribunal had followed its earlier order for the preceding year, which had already been affirmed. In view of the settled position, no error was found in the Tribunal's deletion of the addition.

Conclusion: The question was answered against the Revenue and in favour of the assessee.

Final Conclusion: The tax appeal failed and stood dismissed, leaving the Tribunal's deletion of the section 14A read with Rule 8D addition undisturbed.

Ratio Decidendi: Where the issue stands concluded by a binding decision in the assessee's own case for an earlier year, the same view is to be followed and the corresponding disallowance cannot be sustained.

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