Review under sales tax law cannot reopen a final revisional decision on the basis of a later collateral order.

Statutory review under the sales tax law was unavailable because the applicant failed to show any new and important matter that, despite due diligence, could not have been produced earlier. A subsequent collateral penalty order concerning the alleged first seller did not justify reopening the final revisional decision, especially when the supposed supporting orders were already unavailable or had been reversed. The Court held that the intelligence officer could not disregard or alter the effect of the final revisional judgment through collateral proceedings, and the review petition was not maintainable on the grounds urged.

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Issues: Whether the review petition could be entertained on the basis of a subsequent penalty order and alleged new facts, and whether the final order in the sales tax revision called for review under the statutory review power.

Analysis: The review was sought on the footing that a later order concerning the alleged first seller showed that the turnover earlier attributed to the assessee was actually that of another dealer. The Court found that the later order could not justify review because the alleged supporting orders were already unavailable or had been reversed, the review petitioner had not shown any new and important matter that was beyond knowledge despite due diligence, and the subsequent order itself was passed in disregard of the final revisional judgment. The Court also held that the intelligence officer had no authority to sit in judgment over the final revisional decision or to alter its effect by collateral proceedings.

Conclusion: The review petition was not maintainable on the grounds urged and was liable to be dismissed.

Final Conclusion: The final revisional judgment remained undisturbed, and the statutory review power could not be used to reopen it on the basis of the subsequent collateral order.

Ratio Decidendi: Review under the sales tax statute is unavailable unless the applicant demonstrates a legally cognizable new and important matter that could not, despite due diligence, have been produced earlier; a subsequent collateral order cannot be used to undermine the finality of a revisional decision.

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