Dismissing the Review petition   against the dismissal of writ petition in Distributors India (South) v. UOI (NO. 1) (2022) 446 ITR 163 (All)(HC)  the Court held that  (i) Review proceedings are not by way of appeal and have to be strictly confined to the scope and ambit of rule 1 of Order 47 of the Schedule to the Code of Civil Procedure, 1908. (ii) The power of review may be exercised when some mistake or error apparent on the face of the record is found. But an error on the face of record must be such an error which must strike one on merely looking at the record and would not require any long-drawn process of reasoning on points on which there may conceivably be two opinions. (iii) The power of review may not be exercised on the ground that the decision was erroneous on the merits. Court also held that  by raising the question, the assessee was seeking a rehearing of the writ petition, which was not permissible in the name of review of the judgment. The court had refused to interfere with the notice under section 148 issued on the basis of the reasons recorded by the Assessing Officer that although the assessee had produced the books of account, annual report, profit and loss account and balance sheet, the requisite material facts were embedded in such a manner that the material facts could not be discovered by the Assessing Officer. This material which came to light upon investigation conducted subsequent to the passing of the assessment order, and would certainly amount to fresh tangible material giving rise to reason to believe that certain income has escaped assessment necessitating initiation of reassessment proceedings. This finding did not suffer from any error which may be said to be apparent on the face of the record so as to warrant a review of the judgment. (AY.   2013-14)