Statutory tribunal powers remain confined to express review and rectification limits; counsel's mistaken withdrawal is not an apparent record error.

A statutory tribunal may review or rectify only within the precise limits of the enabling provision. Under section 36(6)(a) of the Madras General Sales Tax Act, review was confined to discovery of new and important facts not within knowledge and not producible with due diligence; a counsel's mistaken withdrawal of an appeal did not satisfy that test. Under section 55, rectification was limited to an error apparent on the face of the record, meaning a manifest error from the record itself, not one requiring outside material or fresh inquiry. Inherent power could not be used to expand that restricted jurisdiction.

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Issues: (i) Whether the Tribunal could review or set aside its earlier order under section 36(6)(a) of the Madras General Sales Tax Act, 1959 on the basis of counsel's mistaken withdrawal of the appeal. (ii) Whether the Tribunal could grant relief under section 55 of the Madras General Sales Tax Act, 1959 or on any inherent power, on the ground that there was an error apparent on the face of the record.

Issue (i): Whether the Tribunal could review or set aside its earlier order under section 36(6)(a) of the Madras General Sales Tax Act, 1959 on the basis of counsel's mistaken withdrawal of the appeal.

Analysis: Section 36(6)(a) permitted review only on discovery of new and important facts not within knowledge and not producible with due diligence when the order was made. The asserted basis was not discovery of new facts, but a claimed mistake by counsel in withdrawing the appeal. That ground did not fit within the statutory language of review.

Conclusion: The application was not maintainable under section 36(6)(a), and the Tribunal was correct in refusing relief on that ground.

Issue (ii): Whether the Tribunal could grant relief under section 55 of the Madras General Sales Tax Act, 1959 or on any inherent power, on the ground that there was an error apparent on the face of the record.

Analysis: Section 55 empowered rectification only of an error apparent on the face of the record. Such an error must be manifest, self-evident, and discoverable from the record itself; it cannot be established by relying on materials outside the record or by an inquiry into matters first brought forward in a review or rectification proceeding. A counsel's mistaken withdrawal of the appeal was not such an apparent error. The reference to inherent power did not enlarge a special statutory tribunal's authority beyond the limits expressly fixed by the statute, especially where the statute itself confined the remedy to a specific ground.

Conclusion: No relief was available under section 55, and no inherent power could be invoked to override the statutory restriction.

Final Conclusion: The petition failed because neither the review provision nor the rectification provision could be used to undo the withdrawal and dismissal of the appeal.

Ratio Decidendi: A statutory tribunal can rectify or review only within the exact limits of the enabling provision, and a claimed mistake of counsel in withdrawing an appeal is not an error apparent on the face of the record nor a basis for enlarging jurisdiction by invoking inherent power.

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