Rectification jurisdiction is time-bound: a belated application could not invoke mistake-correction power under sales tax law.

Rectification under the U.P. Sales Tax Act was confined to mistakes apparent on the face of the record and had to be sought within three years from the date of the order. The Court held that, on the facts accepted by the High Court, the rectification application was filed after expiry of that period, with no material to displace that finding. Because the request was time-barred, rectification jurisdiction did not arise, and the later amendment did not assist on the record before the Court. The challenge to the High Court's view therefore failed.

---

---

Issues: Whether the rectifying authority could entertain and dispose of an application under section 22 of the U.P. Sales Tax Act, 1948 beyond the prescribed three-year period, and whether the High Court was right in holding the rectification order without jurisdiction.

Analysis: Section 22 allowed rectification of mistakes apparent on the face of the record within three years from the date of the order sought to be rectified. The Court noted that the relevant application for rectification was made after the expiry of the three-year period on the facts accepted by the High Court, and there was no material to displace that finding. In view of the belated application, the question of exercising rectification jurisdiction did not arise. The later amendment did not assist the appellant on the facts found in the record.

Conclusion: The challenge to the High Court's view failed. The rectification order was not shown to have been made within time, and the appeal was dismissed.

---