Rectification power permits correcting an obvious assessment year error for undisclosed income, validating the Tribunal's supplementary order.

The note addresses whether the Tribunal may, under rectification jurisdiction, correct an obvious misallocation of undisclosed income to an incorrect assessment year. It states that an error demonstrable without additional evidence and resulting from a clear misplacement of income constitutes an error apparent on the face of the record, permitting correction by a supplementary/rectification order rather than by review. Applying the statutory scheme for determining the previous year for undisclosed income, the Tribunal's power to rectify the assessment year is affirmed and the corrective supplementary order is to be treated as a valid rectification order that stands.

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Issues: Whether the Income-tax Appellate Tribunal was competent to correct its earlier order by passing a supplementary order (rectification) altering the assessment year for an item of undisclosed income.

Analysis: The issue concerns the scope of the Tribunal's power to correct an error apparent on the face of the record. The relevant legal framework includes the provisions dealing with references to the High Court and rectification powers. An error that is demonstrable without additional evidence and that results from a clear misplacement of income into an incorrect assessment year qualifies as an error apparent on the face of the record. Where income is from an undisclosed source and the statutory scheme governing the determination of the previous year applies, the Tribunal may correct an obvious mistake as to the assessment year under rectification jurisdiction rather than by exercising a review power.

Conclusion: The Appellate Tribunal was competent to correct its earlier order by rectification of an error apparent on the face of the record (i.e., the supplementary order is competent and is to be treated as an order under the rectification provision in the statute), and the Tribunal's corrective order stands.

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