Finality in tax valuation disputes bars repeated litigation on the same issue where earlier Tribunal decisions were left unchallenged.

Where valuation of captive-clearance car carrier bodies had already been finally decided in the assessee's own case, the Tribunal held that the same dispute could not be reopened for a later period merely by taking a contrary view. Because the earlier orders had not been challenged by the Revenue and had attained finality, the authorities were bound to follow them under judicial discipline. Repeated litigation on the identical question was impermissible, and the impugned order could not be sustained. The order was set aside and relief followed for the assessee.

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Issues: Whether the impugned order could be sustained when the valuation dispute and related demand had already been finally decided in the appellant's favour in earlier proceedings, and whether repeated litigation contrary to that decision was permissible.

Analysis: The valuation of the captive-clearance car carrier bodies had already been examined and decided by the Tribunal in the appellant's own case. The earlier orders were not appealed against by the Revenue and were treated by the adjudicating and appellate authorities as having attained finality. In such circumstances, a contrary view in the same dispute for a subsequent period could not be sustained, as that would offend judicial discipline and permit the same issue to be reopened despite an existing final decision.

Conclusion: The impugned order was not sustainable and was set aside; the appeal was allowed.

Final Conclusion: The adjudication could not be reopened contrary to the earlier final decision in the appellant's favour, and the assessee obtained relief.

Ratio Decidendi: Where a tax dispute on the same issue has already been finally decided in the assessee's favour and has attained finality, authorities must follow that decision and cannot permit repeated litigation on the same question in violation of judicial discipline.

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