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Issues: Whether the High Court could review its order under section 22(7)(a) of the Andhra Pradesh General Sales Tax Act, 1957, on the basis of a subsequent Supreme Court decision taking a contrary view.
Analysis: The statutory power of review under section 22(7)(a) was held to be confined to facts that existed when the revisional order was made but were not before the Court at that time. A later judicial decision was not treated as such a fact. The scheme of the Act showed that the review jurisdiction was only a limited corrective power in revision, and not a power to make a fresh order on new developments. The Court distinguished the wider language of section 34(1)(b) of the Indian Income-tax Act, 1922, where "information" could include subsequent judicial decisions, and held that that reasoning could not be applied to section 22(7)(a).
Conclusion: A subsequent decision of the Supreme Court is not a fact within section 22(7)(a), and the High Court cannot review its revisional order on that basis.
Ratio Decidendi: A statutory review power confined to "facts which were not before" the Court covers only pre-existing facts not then placed before the Court, and does not extend to later judicial decisions or subsequent changes in law.