Coordinate bench precedent binds later Tribunal consideration of section 10(23C)(vi) exemption and requires implementation of earlier entitlement.

An assessee's entitlement to exemption under section 10(23C)(vi) from assessment year 2018-19 onwards was treated as already settled in its own earlier proceedings, and the later Tribunal bench held that the Assessing Officer had to implement that earlier direction. Applying judicial discipline, the Tribunal followed the coordinate bench decision in the assessee's case and noted that such a ruling remains binding unless distinguished or set aside. The issue was decided in favour of the assessee, and the claimed exemption was directed to be granted for the relevant assessment year.

---

---

Issues: Whether the assessee was entitled to exemption under section 10(23C)(vi) of the Income-tax Act, 1961 from assessment year 2018-19 onwards and whether the Assessing Officer was bound to act accordingly.

Analysis: The assessee's entitlement to approval under section 10(23C)(vi) had already been determined in earlier proceedings in its own case for assessment year 2018-19. The Tribunal noted that the later administrative order did not correctly implement that direction and that, in view of the coordinate bench decision already operating in the assessee's favour, it was bound to follow the earlier ruling as a matter of judicial discipline.

Conclusion: The issue was decided in favour of the assessee. The assessee was held entitled to exemption under section 10(23C)(vi) from assessment year 2018-19 onwards and the Assessing Officer was directed accordingly.

Final Conclusion: The appeal succeeded and the assessee obtained the claimed exemption for the relevant assessment year.

Ratio Decidendi: A coordinate bench decision in the assessee's own case is binding on a later bench of the Tribunal unless distinguished or set aside, and the authorities must implement the entitlement already adjudicated.

---