PCIT-1 Vs Airbus India Pvt Ltd. (Karnataka High Court)
The Karnataka High Court dismissed the Revenue’s review petition, holding that the earlier order—quashing the revised Form-2 issued under the DTVSV Scheme, 2024 and directing consideration of the rectification application—did not suffer from any error apparent on the face of the record. The Revenue had sought review on the ground that CBDT Circular No. 19/2024 (FAQ 47) was not considered earlier and would alter the outcome. However, the Court held that review jurisdiction is limited and cannot be used to re-argue the case or introduce new contentions that require detailed reasoning.
The Court emphasized that since the rectification application was filed prior to issuance of the impugned Form-2 and the appeal was still pending before the High Court, the earlier directions were legally justified. It further reiterated settled principles that review is not an appeal in disguise and can be entertained only in cases of patent errors. Accordingly, finding no such error, the review petition was dismissed.
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
In this petition, petitioners seek the following reliefs:
“i) Review the order dated 28.10.2025 passed by this Hon’ble Court in W.P.No.24690/2025.
ii) To pass such other suitable orders as this Hon’ble Court deems fit to be granted in the facts and circumstances of the case in the interest of justice and equity.”
2. Heard learned counsel for the petitioners and learned counsel for the respondent and perused the material on record.
