The Tribunal held that a prior appellate determination that a...

The Tribunal held that a prior appellate determination that a show cause notice did not satisfy the statutory notice requirement attained finality where not appealed, and subordinate authorities must follow that ruling; consequence: de novo proceedings premised on the discarded proposition are tainted and impermissible. The remand was confined to identifying the triggering event and computing the limitation period for issuing the statutory notice; consequence: only those factual and temporal issues may now be re-examined. Executive review channels and administrative supervisory provisions were recognised as the proper remedies rather than reviving settled legal propositions; consequence: reopening settled law is proscribed.

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