Rectification power is limited to patent errors; it cannot reopen final compounding orders or revisit disputed facts.

Section 37 rectification is confined to correcting a mistake apparent from the record and does not permit review, reopening of a final compounding order, or reappreciation of evidence. New pleas such as exemption of stock and alleged duress at the time of survey, raised after finality had attached, require fresh examination of facts and law and therefore fall outside the rectification power. A claim of pressure made after inordinate delay, without reliable supporting material, cannot invalidate a concluded compounding order through section 37.

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Issues: Whether the assessee could invoke rectification under section 37 to reopen a final compounding order under section 72(3) on the plea that the stock was exempt and that the composition was obtained under pressure.

Analysis: Section 37 permits correction only of a mistake apparent from the record. It does not confer a power of review or authorise reappreciation of evidence. The assessee's application did not point out any arithmetical or patent error in the final compounding order. Instead, it sought to raise new pleas, including exemption of carpets and alleged duress at the time of survey, long after the compounding order had attained finality. Such contentions required a fresh examination of facts and law and were therefore outside the limited scope of rectification. A plea of pressure raised after an inordinate delay, without reliable supporting material, could not invalidate the final order through section 37.

Conclusion: The rectification application was not maintainable and the rejection of the application was . The challenge to the final compounding order failed.

Ratio Decidendi: Rectification provisions cannot be used to review or reopen a final order by introducing disputed questions or reappreciating evidence; only an obvious mistake apparent from the record can be corrected.

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