Belated tax exemption application treated as fresh filing; review and rectification were unavailable under the governing provisions.

A belated joint application for tax exemption and related reliefs was treated as a fresh application, not a review, because the governing review provision required filing within 30 days under rule 25(3)(c). Section 22 of the U.P. Trade Tax Act, 1948, which allows rectification of mistakes apparent on the record, was held inapplicable because several matters raised had not been covered by earlier orders or prior appeals. The lower authorities were justified in rejecting the application, and the High Court erred in interfering with that rejection; the rejection was therefore upheld.

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Issues: Whether a belated joint application for tax exemption and related reliefs could be entertained as a review or rectification application, and whether section 22 of the U.P. Trade Tax Act, 1948 applied to the facts.

Analysis: The application made on 25 December 1998 was held to be a fresh and belated application, not a review, because the only provision for review required filing within 30 days under rule 25(3)(c). The Court further held that section 22, which permits rectification of mistakes apparent on the record, had no application to the facts. Many matters raised in the application had not been covered by earlier orders and were not the subject of prior appeals, so the lower authorities were justified in rejecting it. The High Court was therefore found to have erred in interfering with that rejection.

Conclusion: The belated application was not maintainable, section 22 did not apply, and the rejection by the authorities below was upheld; the High Court's contrary order was set aside.

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