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    <description>Section 12-A(6)(a) of the Madras General Sales Tax Act was construed broadly to permit review on the basis of facts not before the Appellate Tribunal earlier, including fresh evidentiary material supporting a plea of non-liability that had already been raised or is raised for the first time at review. The phrase was held not to be confined to wholly new basic facts, and the provision was not read down by importing the narrower limits of Order 47 Rule 1 CPC. Where all material was already before the Tribunal but it omitted to decide an argued issue, the defect was treated as a mistake apparent from the record, remediable by rectification or remand, not review.</description>
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      <link>https://www.taxtmi.com/caselaws?id=127687</link>
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