Rectification jurisdiction and exemption circulars remain distinct: later statutory amendment did not extinguish the earlier relief scheme.

Rectification under section 25A is confined to an obvious and patent mistake apparent from the record; it cannot be used where the issue requires reasoning or admits of more than one view. On that basis, the assessing authority was not justified in reopening the exemption granted under the then-operative circulars. The earlier circulars granting exemption for turnover relating to goods manufactured from tax-paid iron scrap were also not treated as having become void by reason of explanation II inserted in the Fourth Schedule by Act 13 of 1982, because the circular scheme and the later statutory scheme were considered distinct and not substitutes for each other.

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Issues: (i) Whether the assessing authority was justified in invoking rectification jurisdiction under section 25A of the Karnataka Sales Tax Act, 1957 on the facts of the case; (ii) Whether the Government circulars dated 28 June 1976 and 5 July 1976 granting exemption to turnover relating to goods manufactured out of tax-paid iron scrap became void because of explanation II inserted in the Fourth Schedule by Act 13 of 1982.

Issue (i): Whether the assessing authority was justified in invoking rectification jurisdiction under section 25A of the Karnataka Sales Tax Act, 1957 on the facts of the case.

Analysis: A power of rectification can be exercised only where there is an obvious and patent mistake apparent from the record. If the controversy requires a long process of reasoning or admits of two possible views, the matter does not fall within the scope of rectification. The exemption had been granted on the basis of the circulars then in force, and the issue whether that position could later be displaced by the amendment was not an obvious error on the face of the record.

Conclusion: The assessing authority was not justified in invoking section 25A.

Issue (ii): Whether the Government circulars dated 28 June 1976 and 5 July 1976 granting exemption to turnover relating to goods manufactured out of tax-paid iron scrap became void because of explanation II inserted in the Fourth Schedule by Act 13 of 1982.

Analysis: The exemption scheme under the circulars and the scheme introduced by explanation II were treated as distinct. The circulars were issued to relieve the burden created after the legal position declared in Pyare Lal Malhotra, whereas the later amendment dealt with a different statutory scheme involving levy with adjustment for tax already paid on inputs. The later amendment was therefore not treated as a substitution that retrospectively extinguished the earlier exemption circulars.

Conclusion: The circulars did not become null and void by reason of explanation II in the Fourth Schedule.

Final Conclusion: The rectification and appellate orders could not stand, and the original assessments were restored.

Ratio Decidendi: Rectification is impermissible where the alleged error is not obvious and patent, and a later amendment will not nullify an earlier exemption scheme unless the legislative scheme clearly substitutes or overrides it in the same field.

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