Limited review jurisdiction under Section 23B(7) did not extend Amnesty protection to appeals or revisions filed after the order.

Review jurisdiction was confined to a narrow reconsideration of the earlier order, and no reviewable error was shown. Section 23B(7) of the Kerala General Sales Tax Act, 1963 was construed literally to apply only where the amount settled under the Amnesty provision had already been the subject of an appeal or revision; its refund or recovery consequences were likewise tied to such pending appellate or revisional proceedings. On that construction, the provision could not be extended to appeals or revisions instituted after the Amnesty order. The cited precedents were treated as distinguishable, and reliance on Section 41(7)(b) did not justify interference. The review petitions therefore failed on merits.

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Issues: Whether the review petitions disclosed any error warranting interference with the earlier judgment, particularly on the construction of Section 23B(7) of the Kerala General Sales Tax Act, 1963 and its application to appeals or revisions filed after the Amnesty order.

Analysis: The review jurisdiction was confined to a limited re-examination of the earlier order. Reading Section 23B(7) literally, continuation of an appeal or revision is permissible only where the amount settled under the Amnesty provision had already been the subject matter of an appeal or revision. The provision also contemplates refund or recovery only as a consequence of such pending appellate or revisional proceedings. On that construction, the protection of Section 23B(7) could not be extended to proceedings instituted after the Amnesty order. The cited precedents were treated as distinguishable on law and facts. No reviewable error was shown in the earlier judgment, and the argument based on Section 41(7)(b) of the Kerala General Sales Tax Act, 1963 did not advance the case for interference.

Conclusion: The review petitions were not maintainable on merits and failed.

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