ORDER Utpalendu Bikas Saha, J. 1. This petition is filed by the petitioners-Revenue for review of the judgment and order dated 23.8.2012 passed by this Court in CRP No. 43 of 2012 wherein this Court considering the order of rejection of the revision petition dated 21.10.2011 passed in Rev. case No. 60 of 2011 and the order dated 23.6.2011 passed by the Commissioner of Taxes, the Revisional authority, directed the petitioner revenue, the respondents therein, to adopt the twin test for determining the classification of the seized goods meaning thereby the common parlance test such as the functional utility and pre-dominance of the primary uses of the commodity apart from taking into account other understanding in common parlance such as to consider the product literature and label etc. and thereafter to determine the composition and character of the product on resorting to the scientific test and also ordered granting liberty to the Commissioner of Taxes to take aid from the Deputy Drug Controller for determining the position of the said product to classify the product in controversy having the brand name of 'Betonin AST Tonic' manufactured by M/s. Sangfroid Industries Ltd., IDA, Kothur, Andhra Pradesh with some other observations. Heard Mr. K. Roy, learned Counsel for the review petitioners as well as Mr. S. Deb, learned senior Counsel assisted by Mr. S. Dutta, learned Counsel appearing for the respondent. 2. The brief facts needed to be discussed for disposal of the instant review petition are as follows: The respondent, a registered dealer under Tripura Value Added Tax Act, 2004 (for short hereinafter referred to as 'the, TVAT Act') and the Central Sales Tax Act, 1956 (in short, the CST Act), had filed a revision petition before this Court under Section 72 of the TVAT Act challenging the order dated 21.10.2011 passed in Rev. case No. 60 of 2011 and the order dated 23.06.2011 passed by the Commissioner of Taxes, the Revisional authority as well as the order of seizure dated 25.3.2011 passed by the Superintendent of Taxes, Churaibari, the seizing authority, in Seizure case No. 1549/CRB/10-11 on being seized the goods as declared by the respondent as 'HL medicine' attracting tax @ 5% whereas the seized goods are according to the seizing authority are 'Appetite Tonic' which is taxable @ 13.5% covered by Entry No. 183 under Schedule II(b). 3. 3. The grievance of the respondent-dealer before this Court in the revision petition was that seized goods 'Betonin AST Tonic,' fall under the category of 'drugs' and the tax prescribed for the said product is 5% as covered by Entry No. 67(i) of Schedule II(a) of the TVAT Act whereas tonic is covered by Entry No. 183 of Schedule II(b) which is taxable @ 13.5% and the learned Revenue authority on the plea of mis-declaration of the aforesaid seized goods, namely, 'Betonin AST Tonic' which were shown as HL medicine demanded 13.5% of tax instead of 5% and the other grounds as taken before this Court at the time of hearing of the revision petition was that the Deputy Drugs Controller had in an unambiguous term opined that 'Betonin' is a drug as per definition of 'drugs' under the Drugs and Cosmetics Act, 1940 and the respondent had made that reference for satisfying the revenue authority that the seized goods were the goods within the purview of the drugs and certain documents were also placed before the Revenue authority to demonstrate the correlation with the present case and the previous case, but the Revenue authority did not accept the contention of the respondent-dealer and passed the order as stated supra. Being aggrieved, the respondent-dealer filed the revision petition under Section 72 of the TVAT Act. 4. The petitioners-revenue, i.e. the respondents in the revision petition contested the case by way of filing their affidavit wherein it has been contended that the order of seizure dated 25.3.2011 or the impugned order dated 21.10.2011 cannot be stated to be erroneous or de hors the statutory provisions. More so, the Revisional authority has the power to examine the records of a dealer in the light of the statutory provisions. According to them, the respondent-dealer, has given mis-declaration regarding the seized goods showing them as HL medicine to evade the tax though the said goods are tonic and fall under the Entry No. 183 of the Schedule II(b) of the TVAT Act. 5. Mr. According to them, the respondent-dealer, has given mis-declaration regarding the seized goods showing them as HL medicine to evade the tax though the said goods are tonic and fall under the Entry No. 183 of the Schedule II(b) of the TVAT Act. 5. Mr. Roy, learned Counsel for the petitioners while urging for review of the judgment and order dated 23.8.2012 would contend that a specific entry in a tax statute would override the general entry and the Entry No. 183 of Schedule II(b) of the TVAT Act being a specific entry and the seized goods fallen under the said entry, the respondent dealer cannot claim 'Betonin AST Tonic' as drug falling under Entry No. 67. 6. He has further contended that at the time of argument in the revision petition, as the judgment of the Apex Court in State of Maharashtra Vs. Bradma India Limited (2005) 140 STC 17 had not been filed, the Court allowed the revision petition. Had the same been placed before the Court, then the Court would not have allowed the revision petition as the case in hand is squarely covered by the said judgment. Thus, this Court committed mistake while allowing the revision petition by the impugned judgment and order. More so, in the instant case, the matter of revenue is involved. Thus, the Court should allow the review petition dismissing the revision petition preferred by the respondent dealer. 7. Mr. Deb, learned senior Counsel while countering the submission of Mr. Roy submits that the instant review petition should be dismissed at the threshold as no specific grounds viz (i) discovery of the new and important matter or evidence which after exercising of due diligence was not within the petitioners' knowledge or could not be produced by them at the time when the order was passed; (ii) mistake or error apparent on the face of the record; (iii) or for any other sufficient reasons, have been cited. 8. According to him, the grounds taken by the petitioners-revenue are only for altering the conscious decision of this Court, not for either correcting any apparent error on the face of record or mistake committed by this Court in the judgment and order. In support of his aforesaid contention, he has placed reliance on a decision of the Apex Court in State of West Bengal Vs. In support of his aforesaid contention, he has placed reliance on a decision of the Apex Court in State of West Bengal Vs. Kamal Sengupta, (2008) 8 SCC 612 , particularly, para-22 of the said Report which is reproduced hereunder: 22. The term 'mistake or error apparent' by its very connotation signified an error which is evident per se from the record of the case and does not require detailed examination, scrutiny and elucidation either of the facts or the legal position. If an error is not self-evident and detection thereof requires long debate and process of reasoning, it cannot be treated as an error apparent on the face of the record for the purpose of Order 47 Rule 1 CPC or Section 22(3)(f) of the Act. To put it differently an order or decision or judgment cannot be corrected merely because it is erroneous in law or on the ground that a different view could have been taken by the Court/tribunal on a point of fact or law. In any case, while exercising the power of review, the Court/tribunal concerned cannot sit in appeal over its judgment/decision. 9. The power of a Civil Court to review its judgment/decision is traceable in Section 114 CPC. The grounds on which review can be sought are enumerated in Order 47 Rule 1 CPC, which read as under: 1. Application for review of judgment.- (1) Any person considering himself aggrieved- (a) By a decree or order from which an appeal is allowed, but from which no appeal has been preferred, (b) By a decree or order from which no appeal is allowed, or (c) By a decision on a reference from a Court of small causes, And who, from the discovery of new and important matter or evidence which, after the exercise of due diligence was not within his knowledge or could not be produced by him at the time when the decree was passed or order made, or on account of some mistake or error apparent on the face of the record, or for any other sufficient reason, desires to obtain a review of the decree passed or order made against him, may apply for a review of judgment to the Court which passed the decree or made the order. 10. In BCCI Vs. 10. In BCCI Vs. Netaji Cricket Club, (2005) 4 SCC 741 , the Apex Court while dealing with the provisions of Section 114 as well as Order 47 Rule 1 of the Code noted that the jurisdiction of the High Court in entertaining a review application cannot be said to be ex facie bad in law. Section 114 of the Code empowers a Court to review its order if the conditions precedent laid down therein are satisfied and the said provision of law does not prescribe any limitation on the power of the Court except those which are expressly provided in the said Section of the Code. Order 47 Rule 1 of the Code provides for filing an application for review and such an application for review would be maintainable not only upon discovery of a new and important piece of evidence or when there exists an error apparent on the face of the record, but also if the same is necessitated on account of some mistake or for any other sufficient reason. The Apex Court also noted, inter alia, a mistake on the part of the Court which would include a mistake in the nature of the undertaking may also call for a review of the order. An application for review would also be maintainable if there exists sufficient reason therefore. 11. In Parison Devi Vs. Sumitri Devi (1997) 8 SCC 715 , the Apex Court while considering the provisions of Order 47 Rule 1 CPC has also considered the scope of review jurisdiction of the Court and noted that under Order 47 Rule 1 CPC a judgment may be open to review inter alia if there is a mistake or an error apparent on the face of the record. An error which is not self-evident and has to be detected by a process of reasoning, can hardly be said to be an error apparent on the face of the record justifying the Court to exercise its power of review under Order 47 Rule 1 CPC. In exercise of the jurisdiction under Order 47 Rule 1 CPC it is not permissible for an erroneous decision to be 'reheard and corrected'. A review petition has a limited purpose and cannot be allowed to be 'an appeal in disguise'. In exercise of the jurisdiction under Order 47 Rule 1 CPC it is not permissible for an erroneous decision to be 'reheard and corrected'. A review petition has a limited purpose and cannot be allowed to be 'an appeal in disguise'. The Apex Court further noted that there is a clear distinction between an erroneous decision and an error apparent on the face of the record. While the first can be corrected by the higher forum, the latter only can be corrected by exercise of the review jurisdiction. 12. In Lily Thomas Vs. Union of India, (2000) 6 SCC 224 , the Apex Court considered the law relating to the review and held that: 52. The dictionary meaning of the word 'review' is 'the act of looking, offer something again with a view to correction or improvement'. It cannot be denied that the review is the creation of a statute. This Court in Patel Narshi Thakershi Vs. Pradyumansinghji Arjunsinghji, held that the power of review is not an inherent power. It must be conferred by law either specifically or by necessary implication. The review is also not an appeal in disguise. It cannot be denied that justice is a virtue which transcends all barriers and the rules or procedures or technicalities of law cannot stand in the way of administration of justice. Law has to bend before justice. If the Court finds that the error pointed out in the review petition was under a mistake and the earlier judgment would not have been passed but for erroneous assumption which in fact did not exist and its perpetration shall result in a miscarriage of justice nothing would preclude the Court from rectifying the error. 13. In State of Tripura & Anr. Vs. Dr. Shyam Lal Das, 2013 (5) GLT 408, in which one of us was a party (Saha, J.), a Division Bench of this Court considered the scope of review and the words "any other sufficient reason" and held that: 9. We are of the opinion that the petitioners have failed to show the mistakes committed by this Court at the time of passing the order to be reviewed or the error apparent on the face of the said order and not only that the petitioners also did not show any other sufficient reasons for which the order has to be reviewed. In Moran Mar Basselios Catholicos & Anr. Vs. In Moran Mar Basselios Catholicos & Anr. Vs. Most Rev. Mar Poulose Atthanasius & Ors. , reported in AIR 1954 SC 526 , the Apex Court while approving the decision of the Privy Council in Chhajju Ram V. Neki, AIR 1922 PC 112(D) considered the words 'any other sufficient reason' must mean 'a reason sufficient on grounds, at least analogous to those specified in the rule'. It is also stated that there is a clear distinction between an erroneous decision and an error apparent on the face of the record. As we have already stated that while the first can be corrected by the higher forum and the latter only can be corrected by exercise of the review jurisdiction. Even if we consider the points raised by Mr. Chakraborty are correct, then also according to us, the same cannot be considered as error apparent on the face of the record. 14. In our judgment as impugned in the instant review petition, we have neither expressed any opinion as to whether the seized goods falls within the Entry No. 67 of Schedule ii(a) or Entry No. 183 of Schedule ii(b) of the TVAT Act, rather considering the judgments of the Apex Court in Commissioner of Central Excise Vs. M/s. Wockhardt Life Sciences Ltd., 2012 ALR SCW 2017 and others, we have only directed the petitioners-Revenue, the respondents therein, to adopt the twin test for determining the classification, meaning thereby the common parlance test such as the functional utility and pre-dominance of the primary uses, of the commodity apart from taking into account other understanding in common parlance such as to consider the product literature and label etc. and thereafter to determine the composition and character of the product on resorting to the scientific test and the said direction of us was a conscious decision. We have also granted liberty to the Commissioner of Taxes to take aid from the Deputy Drugs Controller, Govt. of Tripura for determining the composition of the product to classify the product in controversy having the brand name of 'Betonin AST Tonic'. 15. We are in full agreement with Mr. Deb, learned Sr. Counsel that review jurisdiction is not so wide like the appellate jurisdiction and somehow is restricted to the extent the grounds mentioned in the Order 47 Rule 1, CPC. 15. We are in full agreement with Mr. Deb, learned Sr. Counsel that review jurisdiction is not so wide like the appellate jurisdiction and somehow is restricted to the extent the grounds mentioned in the Order 47 Rule 1, CPC. In the instant case, the grounds which have been taken for review of our earlier order, do not fall within the parameters of Order 47 Rule 1, CPC. 16. We have also considered Bradma India Ltd. (supra). In the aforesaid case, the question arose as to whether the Tribunal was right in holding that 'electronic cash register' sold by the applicant was covered by Entry 90 of Schedule C Part II and not by Entry 97(b) of Schedule C Part II appended to the Bombay Sales Tax Act, 1959 and as to whether the Tribunal was right in holding that various functions carried on by the machine were only subsidiary functions and that, therefore, the cash register was essentially only a cash register and could not be considered as an electronic system, appliance or instrument and the High Court answered the question in favour of the assessee contrary to the opinion expressed by the Tribunal in favour of the revenue and the Apex Court while setting aside the order of the High Court noted that the language of Entry 97(b) clearly shows, by use of the phrase "other than those specified elsewhere" that it is not only a residuary entry but also that electronic systems, instruments, etc. may be classified under other entries. Entry 90 on the other hand does not contain any words of limitation. The items mentioned therein would cover every species thereof irrespective of the mode of their operation. Cash registering machines are specifically mentioned. In the absence of any limitation or qualification as to the different kinds of cash registering machines, there is no reason to read in any such qualification and limit the entry to particular kinds of cash registering machines. It is significant that by contrast, data processing machines have expressly excluded computers. Were it so excluded, computers would have also fallen within Entry 90. In fact computers are separately dealt with in Entry 97(a). But the exclusion of computers from data processing machines would indicate that the items mentioned in Entry 90 are generic covering all species of such items. Were it so excluded, computers would have also fallen within Entry 90. In fact computers are separately dealt with in Entry 97(a). But the exclusion of computers from data processing machines would indicate that the items mentioned in Entry 90 are generic covering all species of such items. Given the language of the two entries we fail to understand how the High Court could have come to the conclusion that Entry 97(b) was the specific entry and that Entry 90 was the general entry. Such an interpretation goes against the express language of the two entries. 17. As it is stated in the foregoing paragraphs that in the instant case, we have not decided as to whether the seized goods fall either under the Entry 67 of Schedule ii(a) or under Entry 183 of Schedule ii(b) of the TVAT Act. Thus, there is no quarrel with the proposition laid down by the Apex Court in the case of Bradma India Limited (supra) and such decision in no way helps the review petitioners. We are of further opinion that the grounds which are taken in the instant review petition do not fulfill the parameters as prescribed in Order 47 Rule 1. More so, the review petitioners by way of filing this petition questioned the reasons given by us in support of our decision and also wanted re-hearing of the case in the name of review, which is not permissible. In view of the above, the instant review petition is dismissed. Petition dismissed