Review and recall applications are not maintainable where prior disposal adopts higher-court directions, so reopening was refused.

The petition challenged the maintainability of a review/recall application against an order dated 21.08.2025; the court reasoned that the earlier disposal adopted directions issued by the Supreme Court and the applicant sought substitution of that order and permission to file an appeal. Because the matter had been disposed by reference to higher court directions, the court found no factual or legal basis in the present proceedings to reopen or recall the prior disposal and dismissed the review/recall application against the petitioner.

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Issues: Whether the petitioner's application for review/recall of the order dated 21.08.2025 is maintainable.

Analysis: The earlier disposal recorded that the directions issued by the Hon'ble Supreme Court shall govern the petitioner's case. The present application sought a different order in place of the order dated 21.08.2025 and permission to file an appeal. Given that the matter was disposed by reference to the Supreme Court directions, there is no basis in the present proceedings to reopen or recall that disposal on the facts and submissions presented.

Conclusion: The application for review/recall is dismissed and the result is against the petitioner (assessee).

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