“38. The Board of Revenue while reviewing earlier orders passed in exercise of the jurisdiction under Sections 6-D, 15, 25 and 32 is certainly not acting as an appellate authority but is acting only as a revisional authority. It is true that Section 7 of the 1951 Act which is the source of the power of review states that the Board may “review” its orders and “pass such orders in reference thereto as it thinks fit”. We are aware that this Court has held, while explaining the words “as it thinks fit” that those words are to be given a wide meaning. But in the context of review jurisdiction, these words cannot, in our opinion, be treated as equal to an appellate or even revisional jurisdiction. Particularly when we are dealing with review of orders passed in revisional jurisdiction, it is obvious that the review power should be something less than the revisional jurisdiction. We have noticed that under Rule 43 of the Rules made under the 1958 Act, the “officers” who are conferred powers of review can exercise them only in case of “mistakes or errors apparent on the face of the record”. In our considered opinion, the Board's review powers under the 1951 Act are also intended for correction of “mistakes or errors apparent on the face of the record”. On that basis, the powers of the Board's delegate, namely the Commissioner, while exercising review powers of the Board under the 1951 Act, must be held to be equally circumscribed. We disagree in part with the decision of the Orissa High Court in Ramakanta [(1974) 40 Cut LT 917] when it stated that the power of revision under Section 7 of the 1951 Act is wider than Order 47 Rule 1 CPC.”
