Error apparent on record requires a relevant omission; unrelated authorities not earlier cited do not justify rectification.

A rectification application failed because the earlier judgments cited were unrelated to the issue decided in the original order and had not been brought to the Tribunal's notice earlier. Their omission therefore did not amount to an error apparent on the face of the record. No rectifiable mistake was made out, so the original order remained undisturbed.

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Issues: Whether the application for rectification could succeed on the ground that earlier decisions cited in the application had not been considered in the original order and therefore there was an error apparent on the face of the record.

Analysis: The cited judgments were held to be unrelated to the issue actually decided in the original proceedings. Since the applicants themselves ed that those decisions had not been brought to the Tribunal's notice earlier, their omission could not be treated as an error apparent on the face of the record warranting rectification.

Conclusion: The application for rectification was rejected; the finding was against the assessee and in favour of the Revenue.

Final Conclusion: No rectifiable mistake was made out, and the original order was left undisturbed.

Ratio Decidendi: Omission to consider authorities that were neither relevant to the issue decided nor brought to the Tribunal's notice does not constitute an error apparent on the face of the record.

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