On these grounds, the Supreme Court dismissed the SLP both on the ground of delay and on merits, thereby affirming the High Court’s decision. The High Court recorded that the issue was no longer res integra, as it had already been decided by the same Court in Tax Appeal No. 786 of 2023 for Assessment Year 2008–09, involving the same assessee and based on the same Tribunal order. In that earlier decision, the High Court had dismissed the Revenue’s appeal on identical grounds. FULL TEXT OF THE SUPREME COURT JUDGMENT/ORDER1.