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HC held that no error apparent on the face of the record was shown in the earlier order directing consideration of the assessee's pending rectification application and quashing the revised Form-2 under the DTVSV Scheme. The Court noted that the earlier order had already considered the material chronology, including the declaration, initial Form-2, pending rectification request, and the later revised Form-2 issued while the departmental appeal was still pending. Omission to refer to Circular No. 19/2024 did not justify review, because review cannot be used to reopen or reargue issues already decided. The petition was therefore an impermissible attempt at rehearing on merits and was dismissed.
HC held that no error apparent on the face of the record was shown in the earlier order directing consideration of the assessee's pending rectification application and quashing the revised Form-2 under the DTVSV Scheme. The Court noted that the earlier order had already considered the material chronology, including the declaration, initial Form-2, pending rectification request, and the later revised Form-2 issued while the departmental appeal was still pending. Omission to refer to Circular No. 19/2024 did not justify review, because review cannot be used to reopen or reargue issues already decided. The petition was therefore an impermissible attempt at rehearing on merits and was dismissed.
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