Tax deduction claims cannot be reopened in rectification when supporting evidence was not duly placed earlier.

Deduction claims under rule 6(4)(m) of the Karnataka Sales Tax Rules could not be reopened through revision or rectification where the assessee had not properly placed the claims and supporting evidence before the revisional or first appellate authority. The Tribunal had already examined the labour-charges claim in light of the governing law, including the Supreme Court principles relied on by the assessee, and no apparent error justified rectification under section 25A of the Karnataka Sales Tax Act. Additional deduction claims first raised in review were not shown to form part of the earlier adjudication. The High Court treated the impugned orders as based on findings of fact and law and found no substantial question of law.

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Issues: Whether the assessee was entitled to interfere in revision or rectification on the claim for deductions under rule 6(4)(m) of the Karnataka Sales Tax Rules, 1957, and whether the Tribunal erred in refusing to consider additional deduction claims and in holding that no error apparent on the face of the record existed.

Analysis: The dispute turned on the Tribunal's factual findings that the assessee had not duly placed the relevant deduction claims and supporting evidence before the revisional authority or the first appellate authority. The Tribunal had already considered the labour-charges claim in the light of the governing law, including the principles stated in the Supreme Court decision relied upon by the assessee, and had not committed any apparent mistake warranting rectification under section 25A of the Karnataka Sales Tax Act, 1957. The further claims raised in the review proceedings were not shown to have been part of the earlier adjudication, and the High Court found that the impugned orders were founded on findings of fact and law, not on any demonstrable legal error.

Conclusion: No substantial question of law arose, and the challenge to the review and appeal orders failed.

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