Binding precedent bars re litigation of identical tax issues; appeal refused admission on bad debt set off and interest accrual.

Where a tribunal follows binding coordinate-bench and higher-court precedent on identical issues, no substantial question of law arises for admission and the appeal may be dismissed. Applying that principle, the court held that separate provisions for rural and non-rural advances for set-off of bad debts under the Income-tax Act were resolved against admission because the Tribunal relied on coordinate-bench and higher authority precedent; accordingly the appeal was not admitted. Similarly, on whether interest on securities accrues on the due date or daily for broken-period interest, the Tribunal's reliance on existing coordinate-bench precedent meant no favourable answer for the revenue and the appeal was declined admission.

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Issues: (i) Whether two separate provisions for rural and non-rural advances are permissible for set off of bad debts under Section 36(1)(viia) read with Section 26(1)(vii) of the Income-tax Act, 1961; (ii) Whether interest income on securities accrues on the due date of payment of interest or on a daily basis where broken period interest is claimed as expenditure.

Issue (i): Whether two separate provisions for rural and non-rural advances are permissible for set off of bad debts under Section 36(1)(viia) read with Section 26(1)(vii) of the Income-tax Act, 1961.

Analysis: The Tribunal relied on decisions of its coordinate benches relating to earlier assessment years of the same assessee and on higher authority precedent cited by the respondent. No appeal against those coordinate-bench decisions is on record and those decisions were followed by the Tribunal in disposing of the present assessment-year dispute.

Conclusion: The question does not arise for admission and is resolved against admission of the appeal; no favourable answer for the revenue on this point.

Issue (ii): Whether interest income on securities accrues on the due date of payment of interest or on a daily basis where broken period interest is claimed as expenditure.

Analysis: The Tribunal followed the coordinate-bench decision of this Court on the accrual timing of interest income. That precedent addresses the method of accrual and leads to no sustainable basis for answering the question in favour of the revenue.

Conclusion: The question does not admit a favourable answer for the revenue and does not warrant admission of the appeal.

Final Conclusion: Both submitted substantial questions of law are answered by existing Tribunal and court precedents relied upon by the Tribunal, and therefore the appeal is declined admission and dismissed.

Ratio Decidendi: Where the Tribunal has followed binding coordinate-bench and higher-court precedent on identical issues and no contrary appellate challenge to those coordinate-bench decisions exists, a substantial question of law for admission does not arise and the appeal may be dismissed.

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