Limited review jurisdiction bars reopening an order merely for non-citation of a later Supreme Court decision.

Review jurisdiction is confined to limited grounds and cannot be used merely because a later Supreme Court decision was not cited before the single judge. The earlier ruling recognised that the statutory presumption of evasion under the local entry tax law is rebuttable and that the assessing authority may impose a lesser penalty depending on the facts. On that basis, the non-citation of the later decision did not justify reopening the order, and the merits of the penalty under section 7(5) also disclosed no ground for interference. The review application was therefore not maintainable and was rejected.

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Issues: Whether the review application could be entertained on the ground that a Supreme Court decision was not cited before the single judge, and whether the impugned order warranted review on the merits of penalty under section 7(5) of the relevant local entry tax statute.

Analysis: Review jurisdiction is confined to limited grounds and cannot be invoked merely because a decision was omitted from citation. The earlier Supreme Court ruling recognised that the statutory presumption of evasion is rebuttable and that the assessing authority retains discretion to impose a lesser penalty depending on the facts and circumstances. In that setting, the non-citation of the later decision did not furnish a basis for reopening the order, and the merits also did not justify interference.

Conclusion: The review application was not maintainable on the asserted ground and the order under challenge did not call for review; the application failed.

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