Narrow scope of review jurisdiction bars reappreciation of facts; no apparent error justified reopening the earlier tax ruling.

Review jurisdiction remains limited to patent errors apparent on the face of the record; it cannot be used to re-examine the factual matrix or re-appreciate reasoning already considered in appeal. Where the grounds in review merely seek a fresh look at the tax consequences of revaluation of assets on conversion of a firm into a company, the remedy exceeds the narrow scope of review. No apparent error was shown in the earlier judgment, so the review petition was not maintainable and was dismissed.

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Issues: Whether the review petition disclosed any error apparent on the face of the record warranting exercise of review jurisdiction.

Analysis: The grounds raised in review required re-examination of the factual matrix and the reasoning adopted in the earlier judgment on the tax consequences of revaluation of assets on conversion of a firm into a company. Such an exercise would amount to re-appreciation of the circumstances already considered in appeal and would exceed the narrow scope of review. The record did not disclose any patent error that justified recalling the earlier judgment.

Conclusion: The review petition was not maintainable within the scope of review jurisdiction and was dismissed.

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