MASTER CONSTRUCTION CO. (P) LTD. vs STATE OF ORISSA AND ANOTHER

The Supreme Court held that Rule 83 of the Orissa Sales Tax Rules, 1947, limits the Commissioner's jurisdiction to correcting clerical or arithmetical mistakes and does not allow for reargument on merits or new arguments. The Court found that the Commissioner's review of his previous order, which reversed a refund decision based on arguments not presented initially, was improper. The Court emphasized that questions of limitation and the interpretation of appellate orders are arguable issues that should have been raised at the time of the original order, thus ruling in favor of the appellant.