Rectification power cannot reopen earlier appellate orders merely because a later Supreme Court ruling declares the law differently.

Rectification under section 55 is confined to errors apparent on the record and does not amount to a review power. A later Supreme Court declaration of law, even if retrospective in theory, does not by itself make an earlier appellate order manifestly erroneous for rectification purposes. Because the Tribunal could only assess the record as it stood when the appeals were decided, the subsequent change in legal interpretation could not justify reopening those orders. The rectification applications were therefore not maintainable, and the original appellate orders were restored.

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Issues: Whether the Appellate Tribunal could invoke section 55 to rectify its earlier appellate orders on the strength of a subsequent Supreme Court decision, and whether such subsequent declaration of law made the earlier orders mistakes apparent on the face of the record.

Analysis: Section 55 authorises rectification only of an error that is manifest from the existing record and is not intended to confer a power of review. A later decision of the Supreme Court, though declaratory of the law from its inception, does not convert an order validly made at an earlier point of time into an obvious error apparent on the record. The Tribunal, when it originally decided the appeals, could not have anticipated the later ruling, and the subsequent clarification of law could not retrospectively make the earlier orders ex facie erroneous for the purpose of rectification.

Conclusion: The Tribunal had no jurisdiction to rectify the earlier appellate orders merely because a later Supreme Court judgment declared the law differently; the assessees' rectification applications were not maintainable under section 55.

Final Conclusion: The rectification orders were set aside and the original appellate orders were restored, leaving the State's challenge successful.

Ratio Decidendi: A later judicial declaration of law does not by itself create an apparent error in an earlier order for purposes of rectification; the error must be discernible from the record as it stood when the order was made.

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