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Petition challenging validity of reopening assessment u/s 148 dismissed. No final order passed, jurisdictional issue raised for first time in review petition. Statutory remedy available, High Court cannot interfere under Article 226. No apparent error on record to interfere with writ order. Review petition cannot repeat old, overruled arguments or reopen conclusions. Grounds for review under Order 47 Rule 1 CPC not made out. Supreme Court held review requires demonstrating error apparent on record, not error to be searched for. Mere erroneous decision cannot be reviewed. No error apparent warranting interference.
Petition challenging validity of reopening assessment u/s 148 dismissed. No final order passed, jurisdictional issue raised for first time in review petition. Statutory remedy available, High Court cannot interfere under Article 226. No apparent error on record to interfere with writ order. Review petition cannot repeat old, overruled arguments or reopen conclusions. Grounds for review under Order 47 Rule 1 CPC not made out. Supreme Court held review requires demonstrating error apparent on record, not error to be searched for. Mere erroneous decision cannot be reviewed. No error apparent warranting interference.
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