Review jurisdiction is confined to apparent error on the record; prior consideration of Section 115JB defeated the petitions.

Review jurisdiction under Section 114 read with Order 47 Rule 1 CPC is limited to discovery of new and important matter, mistake or error apparent on the face of the record, or other sufficient reason; it cannot be used to reopen concluded adjudication or reargue matters already decided. The HC noted that Section 115JB of the Income-tax Act, 1961 and the decision in Indo Rama Synthetics India Ltd. had already been considered in the earlier judgment, so the claim that they were ignored was contrary to the record. No patent error was shown, and the review petitions did not meet the threshold for interference.

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Issues: Whether the review petitions disclosed any error apparent on the face of the record so as to justify interference under review jurisdiction.

Analysis: Review under Section 114 read with Order 47 Rule 1 of the Code of Civil Procedure is confined to discovery of new and important matter, mistake or error apparent on the face of the record, or other sufficient reason. It cannot be used to reopen concluded adjudication, reargue the matter, or sit in appeal over the earlier decision. The record showed that Section 115JB of the Income-tax Act, 1961 and the judgment in Indo Rama Synthetics India Ltd. had already been considered in the earlier judgment. The contention that they were ignored was therefore contrary to the record and did not disclose any patent error warranting review.

Conclusion: The review petitions did not satisfy the requirements of review jurisdiction and were liable to be dismissed.

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