Final adjudication of exemption issues awaits resolution of residual grounds before the Single Judge, preserving later challenge rights.

Pending residual issues before a Single Judge mean that an exemption issue is not finally adjudicated. The notes state that dismissal of an earlier departmental Special Leave Petition does not merge the High Court decision into the Supreme Court order. A later assessee-favourable decision may be placed before the Single Judge and may govern the pending proceedings. The Special Leave Petitions were closed, with liberty reserved to challenge the reference order after the Single Judge disposes of the matter.

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Issues: Whether the Special Leave Petitions should be entertained when the matter stood remanded to the Single Judge for determination of residual issues.

Analysis: The earlier dismissal of the departmental Special Leave Petition did not cause merger of the High Court decision with the Supreme Court order. Since residual grounds remained pending before the Single Judge, the exemption issue was not finally adjudicated. Any subsequent decision favourable to the assessee could be produced before the Single Judge and could govern the pending proceedings.

Outcome: The Special Leave Petitions were closed, reserving liberty to challenge the reference order after disposal of the matter by the Single Judge.

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