Limitation on rectification powers under sales tax law rendered the Tribunal's belated rectification order void.

Rectification under section 21-A of the Punjab General Sales Tax Act, 1948 is confined to mistakes apparent from the record and must be exercised within two years from the date of the order sought to be rectified. The Tribunal's impugned rectification expressly targeted its 31 March 1992 appellate order, but was made on 10 May 1995, beyond the statutory period. It was therefore without jurisdiction, barred by limitation, and void. The writ petition succeeded and the rectification order was quashed.

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Issues: Whether the Tribunal could validly rectify its earlier appellate order under section 21-A of the Punjab General Sales Tax Act, 1948 after expiry of the statutory period of two years.

Analysis: Section 21-A permits rectification of mistakes apparent from the record within two years from the date of the order sought to be rectified, and the same limitation applies to rectification by the Tribunal. The impugned order expressly rectified the Tribunal's order dated 31 March 1992, not the earlier rectification order. As the impugned rectification was made on 10 May 1995, it was beyond the permissible period and therefore without jurisdiction.

Conclusion: The rectification order was barred by limitation and was invalid.

Final Conclusion: The writ petition succeeded and the impugned rectification made by the Tribunal was quashed on the ground of limitation.

Ratio Decidendi: Rectification under section 21-A of the Punjab General Sales Tax Act, 1948 can be exercised only within the statutory period of two years from the date of the order sought to be rectified, and any rectification made beyond that period is void.

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