Rectification power under sales tax law cannot be used for debatable issues requiring detailed factual or legal examination.

Rectification under section 22 of the U.P. Sales Tax Act was confined to a mistake apparent on the face of the record. Where the original assessment on remand showed that the Sales Tax Officer had applied his mind to the material and deliberately concluded that the turnover was not taxable in the assessee's hands, the alleged error was not patent. A correction requiring detailed examination of facts or law, or elaborate argument, fell outside rectification. The attempted invocation of section 22 was therefore without jurisdiction and the rectification orders could not be sustained.

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Issues: Whether the Sales Tax Officer could invoke the rectification power under section 22 of the U.P. Sales Tax Act on the ground that the original assessment involved a mistake apparent on the face of the record.

Analysis: The original assessment orders on remand showed that the Sales Tax Officer had applied his mind to the material on record and reached a deliberate conclusion that the turnover was not taxable in the petitioner's hands. A power of rectification under section 22 could be exercised only where the error was patent on the face of the record and not where its correction required detailed examination of facts or law or elaborate argument. The alleged mistake was therefore not the kind of manifest error that could be corrected in rectification.

Conclusion: The invocation of section 22 was without jurisdiction and the rectification orders could not be sustained in the assessee's case.

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