Limited tax review jurisdiction excludes later classification orders and cannot be used as a disguised appeal.

A review under the Tamil Nadu General Sales Tax Act is confined to discovery of new and important facts that existed when the original appeal was decided. A later letter or classification order issued after the Tribunal's appellate order could not qualify as a review ground, because subsequent material does not enlarge the statutory review power or justify rehearing the matter as a disguised appeal. The Madras HC held that the Tribunal was not justified in entertaining review on that basis, and the review order was unsustainable; the revision succeeded and the Revenue prevailed.

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Issues: Whether the Tribunal was justified in entertaining a review application under Section 36(6)(a) of the Tamil Nadu General Sales Tax Act, 1959 on the basis of a subsequent letter/classification order issued after the original appellate order.

Analysis: Review under the Act is confined to discovery of new and important facts that were not available when the appeal was decided. A later communication changing the hotel classification, issued after the Tribunal's original order, could not be treated as a fact existing at the time of disposal of the appeal. Such subsequent material did not enlarge the statutory scope of review, and the review jurisdiction could not be used as a disguised appeal for rehearing. The proper remedy, if any, lay in seeking appropriate relief from the Government.

Conclusion: The review was not maintainable on the basis of the subsequent letter, and the Tribunal's order allowing review was unsustainable.

Final Conclusion: The revision succeeded, the Tribunal's review order was set aside, and the Revenue prevailed.

Ratio Decidendi: A review under the sales tax statute can be exercised only on discovery of new and important facts existing at the time of the original decision, and a later order or communication cannot be treated as such a ground for review.

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