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Issues: Whether the Tribunal erred in declining the Revenue's rectification application seeking production of additional evidence under Rule 23 of the CESTAT Procedure Rules, 1982.
Analysis: The Tribunal had already considered the request for additional documents in the earlier round of litigation. The scope of rectification jurisdiction was extremely narrow, and once the Tribunal had examined the relevant aspects in the original proceedings, there was no basis to recall or reopen the order through rectification. In that context, no substantial question of law arose from the order rejecting rectification.
Conclusion: The refusal to entertain the rectification application was upheld, and the Revenue's challenge failed.