No Revision U/s. 264 possible if Assessee Failed to point out mistake apparent on the face of record

Bali Trading (P) Ltd. Vs. Pr. CIT (Madras High Court)

Settled legal principle is that the revision is not an appeal in disguise. The exercise of review jurisdiction could be done only if the applicant is able to point out an error, which is apparent on the face of the order. From the submissions made, this Court finds that the applicant has not been able to point out any error, which is apparent on the face of the order, but the attempt appears to be re-arguing the entire matter, which is impermissible.

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