Review jurisdiction cannot be used to re-argue the case on merits; only narrow grounds justify reconsideration.

Review jurisdiction under Order 47 Rule 1 CPC is confined to patent error, manifest mistake, or discovery of new and material facts unavailable despite due diligence. It cannot be used to reopen the entire matter or to re-argue the case on merits. As the grounds raised sought a fresh hearing without showing any reviewable infirmity on the record or any newly discovered fact, the review petition was not maintainable and was rightly rejected.

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Issues: Whether the review petition disclosed any ground within the limited scope of review under Order 47 Rule 1 of the Code of Civil Procedure, 1908, and whether it could be used to re-argue the tax case on merits.

Analysis: Review jurisdiction is confined to patent error, manifest mistake, or discovery of new and material facts that could not be produced earlier despite due diligence. A review court cannot permit a party to reopen the entire case or convert the review proceeding into an appeal. The grounds raised sought a fresh hearing on merits and did not point to any manifest error on the record or any new fact unavailable earlier. The prior order had also been passed in the presence of both counsel, reinforcing that no reviewable infirmity was shown.

Conclusion: The review petition was not maintainable on the grounds urged and was rightly rejected.

Ratio Decidendi: Review jurisdiction cannot be invoked to re-argue the case on merits and is confined to the narrow grounds recognised under Order 47 Rule 1 of the Code of Civil Procedure, 1908.

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