Rectification requires a manifest record error, not reappreciation of facts, in disputes over origin certificates and customs valuation.

Rectification was refused because no mistake apparent on the face of the record was shown in the prior final order. The Tribunal held that the challenge to acceptance of a SAPTA certificate of origin depended on reappreciation of evidence, not correction of an obvious error, and treated governmental correspondence suggesting misuse, together with the factual record, as more persuasive than the certificate. On valuation, it found that the earlier order had already considered the objection based on Section 14 of the Customs Act, 1962 and the Customs Valuation Rules, 1988, so no manifest error existed. The final order therefore remained undisturbed.

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Issues: Whether the rectification application disclosed any mistake apparent on the face of the record in the final order concerning acceptance of the certificate of origin under SAPTA and the valuation of the imported goods.

Analysis: The application was examined against the record of the earlier final order and the material relied upon, including the governmental correspondence indicating misuse of SAPTA certificates and the factual assertion that cloves were not grown in Pakistan. It was held that a certificate issued by a competent authority is not beyond scrutiny where the factual record shows possible misuse or falsity. The Tribunal treated the Government of India's correspondence and allied material as stronger evidence on the factual issue than the certificate of origin, and held that the challenge sought a reappreciation of facts rather than correction of an obvious error. On valuation also, the Tribunal found that the earlier order had considered the relevant material, including the objection based on Section 14 of the Customs Act, 1962 and the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988, and that no apparent mistake was shown.

Conclusion: No mistake apparent on the face of the record was established, and the rectification request failed.

Final Conclusion: The challenged final order was left undisturbed, with no rectification granted.

Ratio Decidendi: Rectification cannot be used to reopen factual findings or reargue the merits where the alleged error is not manifest from the record itself.

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