Rectification under section 254(2) is limited to apparent mistakes and cannot be used to recall a final appellate order.

Section 254(2) permits only correction of a mistake apparent from the record, and only to that limited extent; it does not authorise the Tribunal to recall its final appellate order in its entirety for a fresh hearing, because that would amount to an impermissible review. A rectifiable mistake must be patent and obvious on the record, not one requiring detailed argument or reappraisal of the merits. On the facts stated, no such apparent error was shown in the earlier order, so the Tribunal could not destroy its final order as a whole under section 254(2).

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Issues: Whether the Tribunal could recall its final order in its entirety under section 254(2) to rectify an alleged mistake.

Analysis: The power under section 254(2) is confined to rectifying a mistake apparent from the record and amending the order to that limited extent. It does not authorise the Tribunal to recall its earlier final order for fresh hearing, because such recall amounts in substance to a review, and the Tribunal has no inherent power of review. A mistake justifying rectification must be patent and apparent, not one requiring elaborate argument or reappraisal of the merits. On the facts, no such apparent error was shown in the earlier order.

Conclusion: The Tribunal had no power to recall and destroy its final order as a whole under section 254(2); the answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: Section 254(2) permits only correction of an obvious mistake apparent from the record and cannot be used to recall a final appellate order or to exercise an impermissible power of review.

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