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2026 Supreme(SC) 845
SUPREME COURT OF INDIA
S.V.N. BHATTI, N.V. ANJARIA, JJ.
The Director Of Income Tax (IT)-I – Appellant
Versus
Superstar Libra Limited – Respondent
Civil Appeal No. 9826 of 2026 @ Special Leave Petition (C) No. 1440 of 2016
Decided On : 30-07-2026
Important Points
Where legal issues in a pending appeal are identical to those previously decided in companion appeals involving the same parties, the court may determine the case by adopting the same reasoning applied in the earlier judgment, ensuring consistency in judicial outcomes.
Subject
Taxation Law - Income Tax
Headnote
(A) Income Tax Law - Assessment - Companion Appeals - Similar issues - When an issue in a current appeal is identical to issues addressed in previous proceedings between the same parties for different assessment periods, the court may adopt the previously recorded view to adjudicate the matter. (Paras 2 and 3)
Facts of the case:
The appeal originated from a tax department challenge regarding an assessment. The matter before the appellate court involved issues that were previously adjudicated in companion appeals between the same parties concerning prior assessment years.
Findings of Court:
Following the adjudication in the companion appeals, where the court had already arrived at a decision on identical matters, the court deemed it appropriate to apply the same reasoning to the current dispute and dismissed the appeal.
Issues: Whether the current tax assessment matter, being similar to previous appeals between the same parties, requires a fresh determination or can be resolved by applying the established outcome of the companion appeals.
Ratio Decidendi: If the legal or factual dispute has been conclusively addressed in previous companion litigation involving the same parties, the court may adopt the earlier judgment's reasoning to determine the current controversy in the interest of consistency.
Result: Appeal dismissed.
Facts of the case:
The appeal originated from a tax department challenge regarding an assessment. The matter before the appellate court involved issues that were previously adjudicated in companion appeals between the same parties concerning prior assessment years.
Findings of Court:
Following the adjudication in the companion appeals, where the court had already arrived at a decision on identical matters, the court deemed it appropriate to apply the same reasoning to the current dispute and dismissed the appeal.
Issues: Whether the current tax assessment matter, being similar to previous appeals between the same parties, requires a fresh determination or can be resolved by applying the established outcome of the companion appeals.
Ratio Decidendi: If the legal or factual dispute has been conclusively addressed in previous companion litigation involving the same parties, the court may adopt the earlier judgment's reasoning to determine the current controversy in the interest of consistency.
Result: Appeal dismissed.
Advocates appeared:
For the Appellant(s) : Mr. Raghavendra P Shankar, A.S.G. Mr. Arijit Prasad, Sr. Adv. Ms. Pallavi Mishra, Adv. Mr. Anmol Chandan, Adv. Mr. A A Pandey, Adv. Mrs. Anita Sahni, Adv. Mr. Nikhil Aradhe, Adv. Mr. Sudarshan Lamba, AOR
For the Respondent(s): Ms. Meera Mathur, AOR Mr. Anand Varma, AOR Ms. Apoorva Pandey, Adv. Mr. Ayush Gupta, Adv.
For the Appellant(s) : Mr. Raghavendra P Shankar, A.S.G. Mr. Arijit Prasad, Sr. Adv. Ms. Pallavi Mishra, Adv. Mr. Anmol Chandan, Adv. Mr. A A Pandey, Adv. Mrs. Anita Sahni, Adv. Mr. Nikhil Aradhe, Adv. Mr. Sudarshan Lamba, AOR
For the Respondent(s): Ms. Meera Mathur, AOR Mr. Anand Varma, AOR Ms. Apoorva Pandey, Adv. Mr. Ayush Gupta, Adv.
| Table of Content |
|---|
| 1. dismissal of appeal based on consistent judicial precedent. (Para 1 , 2 , 3 , 4) |
JUDGMENT :
S.V.N. BHATTI, J.
1. Leave Granted.
2. The present Civil Appeal is a companion appeal to Civil Appeal Nos. 3334-3336 of 2012 between the same parties but for a different assessment year.
3. The issue is substantially similar to that of companion Civil Appeals, and, by adopting the same view, the present Civil Appeal is dismissed.
4. Pending application(s), if any, shall stand disposed of.
