The High Court, being a court of superior jurisdiction and a court of record, can entertain applications for review arising out of judgments passed under S. 260A of the Income-tax Act, 1961. However a review is by no means an appeal in disguise whereby an erroneous decision is reheard and corrected but lies only for patent error apparent on record. Dismissing the petition to review the Court held that, the finding recorded by the Division Bench could not be reviewed for the reason that for the same assessee but for the different assessment year, the same Bench of the Tribunal had accepted the assessee’s plea. The view formed by the Revenue in the present case for the assessment year 1995-96 had been scrutinised not only by the Appellate Tribunal but also by the Division Bench of the court and it had been found to be correct. ( AY.1995 -96)