Consistent litigation positions bar Revenue from disputing an accepted High Court ruling in identical tax matters.

Revenue could not challenge the correctness of a High Court ruling in materially identical matters after having accepted that ruling in another assessee's case arising from the same issue. The Court noted that Revenue had not shown any effective challenge to the earlier decision or any justification for adopting inconsistent positions across identical disputes. On that basis, it declined to examine the correctness of the earlier High Court view in these appeals, and the civil appeals were dismissed.

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Issues: Whether the Revenue could challenge the correctness of a High Court judgment in the present matters after having accepted it in the case of another assessee arising from the same issue.

Analysis: The appeals were based on an earlier High Court decision on the same question. The Revenue had not shown that it had effectively challenged that decision or explained why it could accept it in one assessee's case and dispute it in others. In such circumstances, the Court declined to examine the correctness of the earlier High Court view in these matters.

Conclusion: The challenge by the Revenue was not entertained and the civil appeals were dismissed.

Ratio Decidendi: A party cannot, without just cause, accept a judicial decision in one case and seek to contest its correctness in other materially identical cases.

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