Rectification power cannot reopen a best judgment assessment unless a patent mistake appears on the existing record.

Section 12(1) of the Tripura Sales Tax Act, 1976 permits only correction of an obvious, patent and self-evident mistake apparent from the existing record; it does not authorise review, reappraisal, or reassessment on fresh material. A best judgment assessment under section 9(4) cannot be reopened through rectification merely because it is alleged to be arbitrary or unsupported by sufficient material, where resolving the complaint would require investigation, argument, proof, or fresh examination beyond the record. The rectification request was therefore outside the limited scope of section 12(1), and the assessment could not be revisited on that basis.

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Issues: Whether a best judgment assessment made under section 9(4) of the Tripura Sales Tax Act, 1976 could be rectified under section 12(1) of that Act on the ground that the assessment was arbitrary or unsupported by sufficient material, as a mistake apparent from the record.

Analysis: Section 12(1) confers only a limited power of rectification of mistakes apparent from the record. The expression denotes an obvious, patent and self-evident error discernible from the existing record, and not an error that requires investigation, argument, proof, or a long process of reasoning. The record includes the proceedings on which the order is based, but the authority cannot use rectification to go beyond the record and take into account fresh material. The challenge raised by the petitioner was in substance a request to review the best judgment assessment and re-estimate turnover on the basis of new information, which is outside the scope of rectification.

Conclusion: The petition did not disclose any mistake apparent from the record, and the rectification power under section 12(1) could not be invoked to reopen or reappraise the best judgment assessment.

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