Binding precedent governs appeal disposal, with impugned orders quashed and matters remitted for fresh assessment.

Where the controlling question of law had already been settled by an earlier binding Supreme Court decision, the appeal was disposed of by applying that ruling, with the impugned orders of the High Court, ITAT, CIT(A) and assessing officers set aside and the matters remitted to the assessing officers for fresh consideration after giving the assessees an opportunity to be heard. The matter was therefore not finally determined on merits in this order; it was sent back for decision in accordance with the earlier precedent, with the result operating partly in favour of the Revenue and partly in favour of the assessees.

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Issues: Whether the appeal was to be disposed of in terms of the earlier decision governing the controversy, with the impugned orders quashed and the matter remitted to the assessing officers.

Analysis: The appeal was treated as covered by the earlier decision of the Court. The quoted operative directions in that decision answered the question of law partly in favour of the department and partly in favour of the assessee, set aside the impugned orders of the High Court, ITAT, CIT(A) and assessing officers, and remitted the matters to the respective assessing officers for fresh exercise after granting opportunity to the assessees.

Conclusion: The appeal was disposed of in terms of the earlier decision, with the impugned orders quashed and the matters remitted for fresh adjudication; the outcome was partly in favour of the Revenue and partly in favour of the assessee.

Final Conclusion: The controversy was not finally determined on merits in this order and was sent back for fresh consideration by the assessing officers.

Ratio Decidendi: Where the controlling question of law is already answered by an earlier binding decision, the subsequent appeal may be disposed of by following that ruling and remitting the matter for fresh decision in accordance with it.

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