Review jurisdiction cannot reopen concluded tax issues absent patent error, new matter, or another recognised ground.

Review jurisdiction is confined to discovery of new and important matter, an error apparent on the face of the record, or a similar statutory ground. A review petition that merely repeats arguments already considered or seeks rehearing on the merits does not meet that standard, so it was rejected. Findings on the revised return, fresh claim of exemption, the limits of revisional power under Section 264 of the Income-tax Act, 1961, and the sequence of notices under Sections 142(1) and 143(2) could not be reopened, because the challenge only re-argued concluded issues and disclosed no patent error.

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Issues: (i) Whether the review petition disclosed any ground falling within the limited scope of review under Order XLVII, Rule 1 of the Code of Civil Procedure, 1908; (ii) whether the earlier findings regarding revised return, fresh claim of exemption, the revisional power under Section 264 of the Income-tax Act, 1961, and the sequence of notices under Sections 142(1) and 143(2) of the Income-tax Act, 1961 could be reopened in review.

Issue (i): Whether the review petition disclosed any ground falling within the limited scope of review under Order XLVII, Rule 1 of the Code of Civil Procedure, 1908.

Analysis: Review lies only on discovery of new and important matter, mistake or error apparent on the face of the record, or a reason analogous to those grounds. Repetition of arguments already considered, or a request for rehearing on the merits, does not satisfy the statutory standard. The grounds urged in review were substantially a re-argument of the writ petition and did not disclose any patent error or new material.

Conclusion: The review petition did not satisfy the requirements of review jurisdiction and was not maintainable on that basis.

Issue (ii): Whether the earlier findings regarding revised return, fresh claim of exemption, the revisional power under Section 264 of the Income-tax Act, 1961, and the sequence of notices under Sections 142(1) and 143(2) of the Income-tax Act, 1961 could be reopened in review.

Analysis: The prior judgment had already decided that an assessee cannot revise income through a revised statement in place of a revised return under Section 139(5), that the revisional authority could not permit what the statute did not authorise, and that there was no prescribed sequence requiring notice under Section 142(1) to precede notice under Section 143(2). The review court found that the present grounds merely challenged conclusions already rendered and did not reveal any error apparent on the face of the record.

Conclusion: The earlier findings could not be reopened in review, and the objections were rejected.

Final Conclusion: The judgment under review was left undisturbed, as no permissible ground for review was established.

Ratio Decidendi: Review jurisdiction cannot be used to reargue concluded issues, and it is confined to a patent error, new matter, or a ground analogous to those statutory limits.

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