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Issues: Whether the Tribunal had power to review its final order under Section 86 of the Finance Act, 1994.
Analysis: The application sought reconsideration of the Tribunal's earlier final order. The Tribunal noted that the High Court had only observed that the department could file a review petition if available in law, but no direction had been issued conferring a review power. Since Section 86 of the Finance Act, 1994 did not provide for review of the Tribunal's order, the application could not be entertained. The Tribunal also noted that the appropriate remedy, if any, lay before the Supreme Court.
Conclusion: The Tribunal held that it no jurisdiction to review its final order and rejected the application.