Rectification cannot reopen a contested credit-limit finding already decided in the original order.

Rectification was rejected because the alleged mistake concerned a contested issue already raised in the appeal and decided in the final order. The Tribunal found that the earlier direction to re-quantify duty by applying Notification No. 177/86-C.E. to credit on PVC granules used in Rexine cloth manufacture did not introduce a new issue; the show cause notice and the assessee's reply had already addressed the notification-based credit restriction. Since rectification jurisdiction extends only to patent errors apparent on the face of the record, it could not be used to reopen or delete a reasoned finding on a matter actually in dispute. The earlier credit-limit direction therefore remained undisturbed.

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Issues: Whether the Tribunal's earlier direction to re-quantify duty by applying Notification No. 177/86-C.E. to the credit on PVC granules used in the manufacture of Rexine cloth disclosed any error apparent from the record warranting rectification.

Analysis: The application proceeded on the premise that the earlier final order had introduced a new issue by directing restriction of the available credit to Rs. 5.50 per square metre under Notification No. 177/86-C.E. The records showed otherwise. The show cause notice specifically alleged that the credit utilisation was sought to be arranged so as to circumvent the restriction under Notification No. 177/86-C.E., and the assessee's own reply acknowledged that credit on inputs under Chapter 39.04 was restricted to Rs. 5.50 per square metre of the final product. The challenge on this very point had been raised in the appeal and was directly dealt with in the final order. A rectification jurisdiction could not be invoked to delete a part of the order that had been passed on a contested issue actually arising in the appeal.

Conclusion: No error apparent from the record was shown, and rectification was not warranted.

Final Conclusion: The earlier direction applying the notification-based credit limit remained undisturbed, and the rectification request failed.

Ratio Decidendi: Rectification cannot be used to reopen or delete a reasoned finding on an issue that was in contest and was decided in the original order; only a patent error apparent on the face of the record is corrigible.

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