Review jurisdiction is limited to patent error on the record; it cannot be used for rehearing or reappreciation of evidence.

Review jurisdiction under the Code of Civil Procedure is confined to an error apparent on the face of the record or another recognised ground under Order 47 Rule 1. A review cannot be used to obtain rehearing, reargue facts or law, or invite the court to sit in appeal over its own order. The article applies this principle to an order under section 220(2A) of the Income-tax Act and states that, on the facts discussed, no patent error was shown in the order refusing waiver of interest; the review petition was therefore without merit.

---

---

Issues: Whether the review petition disclosed any error apparent on the face of the record or other sufficient ground warranting review of the order passed under section 220(2A) of the Income-tax Act, 1961.

Analysis: The power of review is confined to the limited grounds recognised by section 114 of the Code of Civil Procedure, 1908 and Order 47 Rule 1 of the Code of Civil Procedure, 1908. A review cannot be used to seek rehearing of the matter or to challenge the order merely because a different view on facts or law is possible. The alleged infirmity must be self-evident and patent from the record, and the reviewing court cannot sit in appeal over its own decision or reappreciate the material already considered. On the facts, no such apparent error was shown, and the order rejecting waiver of interest was found to have been passed on due consideration of the record and the governing legal principles.

Conclusion: No ground for review was made out, and the review petition was liable to be dismissed.

Ratio Decidendi: Review jurisdiction is narrowly confined to a patent error apparent on the face of the record or other recognised grounds, and it cannot be invoked for rehearing or reappreciation of evidence.

---