The answer is in the negative. In Beghar Foundation vs. Justice K. S. Puttaswamy
[2021] 123 taxmann.com 344/278 Taxman, the Supreme Court was considering a review petition, filed against the final judgment and order dated 26 September 2018, passed on the main proceedings. In rejecting the review petition, the Supreme Court observed that no case for review of such judgment was made out, and most importantly on the ground that change in law or subsequent decision/judgment of coordinate or larger bench by itself cannot be regarded as a ground for review.
In Sanjay Kumar Agrawal vs. State Tax Officer (1) and Another (2024) 2 Supreme Court Cases 362 the Supreme Court following the decision in the Constitution Bench in Beghar Foundation (Supra), made the following observations:
“15. It is very pertinent to note that recently the Constitution Bench in Beghar Foundation v. K. S. Puttaswamy (Aadhaar Review – 5 J.), held that even the change in law or subsequent decision/judgment of coordinate Bench or larger Bench by itself
cannot be regard as a ground for review.”
This has been followed by the Bombay High Court in Infantry Security and Facilities vs The Income Tax Officer (Bombay High Court)