Rectification power cannot be used as review when a later ruling changes the legal view of an earlier Tribunal order.

Rectification under section 55 of the Tamil Nadu General Sales Tax Act, 1959 is limited to correcting an error, mistake, defect or imperfection apparent on the record. It cannot be used by the Tribunal to reverse its own earlier decision merely because a later decision of a higher forum has taken a different view; that would amount in substance to review rather than rectification. A subsequent declaration of law may show the correct position, but it does not authorise substitution of a concluded order under the guise of correcting an apparent error. The Tribunal's rectification order was therefore unsustainable.

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Issues: Whether the Appellate Tribunal could invoke section 55 of the Tamil Nadu General Sales Tax Act, 1959 to reverse its earlier order on the strength of a subsequent decision and treat such reversal as rectification of an error apparent on the face of the record.

Analysis: Rectification under section 55 is confined to correcting an existing error, mistake, defect or imperfection apparent on the record. The provision does not authorise an authority, including the Tribunal, to disown or reverse its own earlier decision merely because a later decision of a higher forum has taken a different view. A subsequent declaration of law may show the correct position, but where the Tribunal seeks to reopen and substitute its prior conclusion on that basis, the power exercised is beyond rectification and amounts in substance to review. The earlier order could not therefore be undone under section 55 on the pretext of correcting an apparent error.

Conclusion: The Tribunal had no power under section 55 to reverse its own earlier order on the basis of a later decision, and its rectification order was unsustainable.

Final Conclusion: The revision succeeded and the Tribunal's order granting rectification was set aside, restoring the original assessment addition.

Ratio Decidendi: The power of rectification is limited to correcting an error apparent on the face of the record and cannot be used as a device for substantive review or reversal of a concluded order merely because of a later judicial pronouncement.

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