Rectification power cannot be used to reopen assessment or introduce fresh evidence after completion of assessment.

Rectification under section 55 of the Tamil Nadu General Sales Tax Act, read with section 9(2A) of the Central Sales Tax Act, is confined to correcting an error apparent on the face of the record, such as a clerical or mathematical mistake. It cannot be used to reopen a completed assessment or to place fresh documents before the assessing authority after assessment. A request framed as rectification but seeking reconsideration of the assessment was in substance a review application, which is impermissible. The rectification request was therefore not maintainable and its rejection was upheld.

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Issues: Whether an application styled as rectification under section 55 of the Tamil Nadu General Sales Tax Act, 1959, read with section 9(2A) of the Central Sales Tax Act, 1956, could be used to seek reconsideration of an assessment order by producing additional documents after completion of assessment.

Analysis: Rectification is confined to correction of an error apparent on the face of the record, such as a clerical or mathematical mistake. It does not extend to reopening an assessment or permitting a party to place fresh material before the authority after the assessment has been completed. The attempt made through the rectification letter was in substance a request for review of the assessment order, which is impermissible under the statutory rectification power.

Conclusion: The application was not maintainable as a rectification request and was rightly rejected. The challenge to the rejection failed.

Ratio Decidendi: A rectification power cannot be invoked to achieve a review of an assessment or to introduce new evidence after the assessment is over; it is limited to correcting patent errors on the record.

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