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Issues: Whether the assessment could be rectified under section 22 of the U.P. Sales Tax Act on the basis of 'C' Forms obtained after the assessment order had been made.
Analysis: Rectification under section 22 is confined to a mistake apparent on the face of the assessment record. The mistake must be reflected in the assessment order itself, or in earlier proceedings only if it has a consequential impact on that order. Since the 'C' Forms were not filed before the assessment was completed and were not part of the record when the order was made, the assessment could not be said to suffer from an apparent mistake by reference to those forms.
Conclusion: The claim for rectification was untenable and was rejected against the petitioner.
Final Conclusion: The writ petition challenging the refusal to rectify the assessment was held not maintainable on the asserted ground and was dismissed with costs.
Ratio Decidendi: Rectification is permissible only for a mistake apparent from the record as it stood when the assessment order was made, and post-assessment material cannot be used to create such a mistake.