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<h1>High Court Upholds Strict Review Standards, Denies Appeal Citing Lack of Substantial New Evidence or Manifest Error</h1> <h3>Saurabh Kumar Agarwal Versus The Customs Excise And Service Tax Appellate Tribunal</h3> Saurabh Kumar Agarwal Versus The Customs Excise And Service Tax Appellate Tribunal - 2024:AHC:198801 - DB The Allahabad High Court, in a review application against its order dated 22.11.2024 in Central Excise Appeal No. 14 of 2024, reiterated the limited scope of review jurisdiction under Order 47 Rule 1 CPC, as governed by Section 151 CPC. Citing the Calcutta High Court's summary of Supreme Court precedents (State of West Bengal v. Confederation of State Government Employees, 2019 SCC Online Cal 9181), the Court emphasized that review is permissible only on: (A) discovery of new and important evidence not previously available despite due diligence; (B) an error apparent on the face of the record; or (C) any other sufficient reason, which must be read narrowly within the first two grounds. The Court clarified that 'an error which is not self-evident and has to be detected by a process of reasoning is not an error apparent on the face of the record,' and that review cannot serve as 'an appeal in disguise' (see Sasi v. Aravindakshan Nair, (2017) 4 SCC 692; Haridas Das v. Usha Rani Banik, (2006) 4 SCC 78; Parsion Devi v. Sumitri Devi, (1997) 8 SCC 715). Finding the petitioner's grounds outside these parameters, the Court dismissed the review application.