Honble SHARMA, J.–Invoking supervisory jurisdiction under Article 227 of the Constitution the petitioners have prayed to quash the order dated August 2, 1999 of Divisional Commissioner, Jaipur whereby the revision preferred by the respondent (for short the `assessee) under section 19 of the Rajasthan Land and Building Tax Act, 1964 (for short `1964 Act) was allowed. (2). Contextual facts depict that the Assistant Director, Land & Building Tax Department passed assessment order on December 7, 1991. The Divisional Commissioner Jaipur set aside the said order and remanded the matter back to Assistant Director to arrive at a fresh decision. Pursuant to the direction the Assistant Director issued assessment order on September 14, 1992 determining the value of building of the assessee as on April 1, 1991 Rs. 75,88,500/- and that of land Rs. 14,90,700/-. Tax on the total value of property was determined as Rs. 1,29,188/- per annum payable from April 1, 1991. It appears that tax amounting to Rs. 6,76,158/- was paid by the assessee upto the year 1995-96 as per assessment order dated September 14. 1992. The Audit Party thereafter issued audit memo on November 23, 1994 raising objection about the assessment order. In order to meet the audit objection the Assistant Director issued notice under section 15B of 1964 Act on January 25, 1996 stating therein that since earlier assessment was incorrect, reassessment order was required to be passed. On March 12, 1996 the total value of property was reassessed and order was rendered. The assessee challenged the order by filing appeal but the appeal was rejected. The assessee then preferred revision under section 19 of 1964 Act which was allowed as indicated herein above. (3). The scope of supervisory jurisdiction under Article 227 has been explained by three Judge Bench of the Apex Court in Sadhana Lodh vs. National Insurance Co. Ltd. (2003) 3 SCC 524 thus:-(Para 7) ``7. The supervisory jurisdiction conferred on the High Courts under Article 227 of the Constitution is confined only to see whether an inferior court or tribunal has proceeded within its parameters and not to correct an error apparent on the face of the record much less of an error of law. In exercising the supervisory power under Article 227 of the Constitution, the High Court does not act as an appellate court or the tribunal. In exercising the supervisory power under Article 227 of the Constitution, the High Court does not act as an appellate court or the tribunal. It is also not permissible to a High Court on a petition filed under Article 227 of the Constitution to review or reweigh the evidence upon which the inferior court or tribunal purports to have passed the order or to correct errors of law in the decision. (4). Having heard the rival submissions and scanned the material on record, I notice that after the period of limitation of three years, prescribed under section 19 of 1964 Act, was lapsed, the petitioners did choose to proceed under section 15B which related to escaped assessment. It is trite that on the basis of audit report reassessment could not have been made. In Indian and Eastern News Paper Society vs. Commissioner of Income Tax, (1979) 119 ITR 996 (S.C.) their Lordships of the Supreme Court propounded that the opinion of an internal audit party on a point of law cannot be regarded as `information for the purpose of reopening an assessment. (5). Moreso when the matter was closed on deposing one time tax by the assessee it was not proper for the petitioners to invoke the powers under section 15B of 1964 Act. The impugned order of the Divisional Commissioner does not call for interference under Article 227 of the Constitution. (6). The writ petition lacks merits and stands dismissed. No costs.