Review jurisdiction cannot re-hear an appeal; only an apparent error on the record justifies interference.

A High Court, as a court of record, was treated as having inherent power to review its own order under Article 215 of the Constitution and section 260-A(7) of the Income-tax Act, so the review application was maintainable in principle. However, the applicant failed to show any error apparent on the face of the record. The court held that the review attempt was only a re-argument of the appeal, while the earlier decision had already turned on the limited scope of section 260-A, the failure to discharge the burden concerning donations, the absence of authentic donor records, and the findings of the fact-finding authorities. Review was therefore not used as a substitute for a fresh hearing, and the earlier appellate order remained undisturbed.

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Issues: (i) Whether the High Court had jurisdiction to entertain a review application against its order passed under section 260-A of the Income-tax Act, 1961. (ii) Whether the review applicant had shown any error apparent on the face of the record warranting interference with the earlier dismissal of the appeal.

Issue (i): Whether the High Court had jurisdiction to entertain a review application against its order passed under section 260-A of the Income-tax Act, 1961.

Analysis: The maintainability objection was answered by applying the view that a High Court, being a court of record, has inherent power to review in the light of Article 215 of the Constitution of India and section 260-A(7) of the Income-tax Act, 1961. The review jurisdiction was therefore treated as available in principle.

Conclusion: The review application was maintainable in principle.

Issue (ii): Whether the review applicant had shown any error apparent on the face of the record warranting interference with the earlier dismissal of the appeal.

Analysis: The submissions were found to be a re-argument of the appeal rather than an identification of any evident mistake on the record. The earlier order had proceeded on the limited scope of section 260-A of the Income-tax Act, 1961, the applicant's failure to discharge the burden regarding the donations, the absence of authentic donor records, and the plausibility of the findings recorded by the fact-finding authorities. The governing principle applied was that review cannot be used to re-hear the matter or to correct conclusions which may at best be debatable, unless the error is manifest without a long-drawn reasoning process.

Conclusion: No error apparent on the face of the record was shown, and the review failed on merits.

Final Conclusion: The earlier appellate decision was left undisturbed, and the review jurisdiction was held not to be a substitute for a fresh hearing on the merits.

Ratio Decidendi: Review is confined to correction of an evident error on the face of the record and cannot be used to re-agitate or re-argue issues already decided in appeal.

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