Shanti Prime Publication Pvt. Ltd.
Sec. 260A of Income Tax Act, 1961— Appeal— When does an error cease to be mere error and becomes an error apparent on the face of the record depends upon the materials placed before the Court. If the error is so apparent that without further investigation or enquiry, only one conclusion can be drawn in favour of the applicant, in such circumstances, the review will lie and under the guise of review. The parties are not entitled to rehearing of the same issue but the issue can be decided just by a perusal of the records and if it is manifest can be set right by reviewing the order, thus, as held earlier, if the judgment/order is vitiated by an apparent error or it is a palpable wrong and if the error is self-evident, review is permissible and in this case the High Court has rightly applied the said principles as provided under Order 47 r. 1 CPC, therefore, Court does not find any reason to review the order — Peb steel lioyd (india) ltd. vs. PR. CHIEF CIT [2020] 313 CTR 200 (MP)