Rectification cannot be used as a review; only an apparent record error can justify correction in a tax dispute.

A rectification application cannot be used to reopen the merits of a service tax dispute; only a mistake apparent on the face of the record can be corrected. The Tribunal found that the applicant's objections about premium figures, pre-levy collections, adjustments, and unconsidered payments amounted to a request for review rather than rectification. It also held that the GPA premium figures relied on were not part of the show cause notice annexures, and no evidence established the claimed differences. The jurisdiction objection was not entertained because it had not been raised earlier. No apparent error was shown, so rectification was rejected.

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Issues: Whether the record disclosed any mistake apparent on the face of the order so as to justify rectification in relation to the service tax demand and the Tribunal's jurisdiction.

Analysis: The application sought reconsideration of the entire case on the footing that the premium figures were wrongly appreciated, that certain collections related to periods before levy, and that some adjustments and payments were not taken into account. On scrutiny of the records, the Tribunal found that the premium shown in the returns was lower than the premium actually collected, that the GPA premium figures relied on by the applicant were not part of the annexures to the show cause notice, and that no evidence established the correctness of the claimed differences. The objection that the appeal lay before another forum was also not entertained because it had not been argued earlier. A rectification application cannot be used to review the decision, and only an error apparent on the face of the record can be corrected.

Conclusion: No mistake apparent on the face of the record was shown, and the request for rectification was rejected.

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