Rectification is limited to patent errors apparent on the record; it cannot be used to re-argue merits or evidence.

Rectification is confined to obvious and patent mistakes apparent on the face of the record and cannot be used to re-appreciate evidence, reassess submissions, or seek a fresh view of the factual inferences. Allegations that the earlier order misread a notification, witness statement, or other evidence required reconsideration on merits rather than correction of an apparent error. A rectification application is not a substitute for rehearing the appeal. No mistake apparent from the record was shown, so the rectification application was liable to be dismissed.

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Issues: Whether the rectification application disclosed any mistake apparent from the record warranting correction of the final order.

Analysis: The scope of rectification is confined to obvious and patent mistakes. It does not permit re-appreciation of evidence, re-valuation of submissions, or a fresh examination of factual inferences merely because another view is possible. Allegations that the earlier order misread the notification, the witness statement, or the evidence, or failed to accept the assessee's preferred inference, were matters requiring reconsideration on merits and not correction of an apparent error. A rectification application cannot be used as a substitute for rehearing the appeal.

Conclusion: No mistake apparent from the record was shown, and the rectification application was liable to be dismissed.

Ratio Decidendi: Rectification lies only for an obvious and patent error apparent on the face of the record and cannot be invoked to re-argue the merits or to substitute one possible view of the evidence for another.

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