Rectification cannot be used to raise a fresh sales tax exemption claim never made during assessment.

Rectification under section 43 of the Kerala General Sales Tax Act is limited to mistakes apparent on the face of the record, and cannot be used to introduce a fresh exemption claim that was never raised before completion of assessment. Because the exemption was conditional and required supporting documents and proof of compliance with the notification, the absence of any such claim or materials at the assessment stage meant there was no assessable record error on that ground. Once assessment is completed, the authority is functus officio except as permitted by statute, so a new exemption plea cannot be entertained through rectification.

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Issues: Whether a claim for exemption from sales tax, not raised in the returns, replies, or at any time before completion of assessment, could be introduced for the first time in rectification proceedings under section 43 of the Kerala General Sales Tax Act as an error apparent on the face of the record.

Analysis: Rectification under section 43 is confined to mistakes apparent on the face of the record. A claim for exemption that was never made before completion of assessment does not form part of the assessment record. The exemption in question was conditional and required supporting documents and proof of satisfaction of the notification conditions. Since neither the claim nor the supporting materials were placed before the assessing authority at the assessment stage, the completed assessments could not be treated as mistaken on that ground. After assessment, the authority becomes functus officio except to the extent permitted by statute, and a fresh exemption claim cannot be introduced through rectification.

Conclusion: The claim for exemption could not be entertained in rectification proceedings, and the rejection of the rectification application was correct.

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