Retrospective cancellation of registration challenged; review petition rejected for seeking re argument and no error found

Retrospective cancellation of registration was invalidated because the original show cause notice lacked reasons and the petitioner was not placed on prior notice, rendering the impugned order defective; the court recorded those findings and refused to reopen or re-decide concluded arguments. The review applicant's challenge amounted to rearguing overruled contentions, but review jurisdiction cannot substitute for an original hearing; the court found no error apparent on the face of the record or miscarriage of justice and therefore dismissed the review petition.

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Issues: Whether the review petition challenging the High Court's order dated 30 January 2025 (which modified retrospective GST cancellation to take effect from the date of the Show Cause Notice) is maintainable and whether there is any material or manifest error on the face of the record warranting review.

Analysis: The Court applied the settled principles governing review jurisdiction (including grounds such as discovery of new evidence, mistake apparent on the face of the record, or any other sufficient reason) and the limits on review (that it is not an appeal in disguise, cannot reopen concluded adjudications, and requires a manifest error undermining the order). The Court examined the earlier finding that the original Show Cause Notice lacked reasons supporting retrospective cancellation and failed to place the petitioner on prior notice of such intent, which formed the basis for modifying the effective date of cancellation. The review applicant (revenue) advanced concerns about wider repercussions but did not demonstrate any new material or any error on the face of the record that would meet the strict review standards; nor did it show that the earlier order resulted in a miscarriage of justice or relied upon a patent factual or legal error requiring correction.

Conclusion: The review petition is not maintainable and there is no material or manifest error on the face of the record; the review is rejected and the earlier order stands.

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