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Issues: Whether the Tribunal could invoke rectification jurisdiction under Section 21-A of the Punjab General Sales Tax Act, 1948 to revise its earlier order on the ground that the amendment to Rule 29(xii) by notification dated 15.4.2002 was not retrospective and the earlier view treating it as clarificatory was erroneous.
Analysis: The scope of rectification under Section 21-A is confined to mistakes apparent from the record. Such a mistake must be patent, obvious, and capable of correction without undertaking a long-drawn process of reasoning. A debatable issue of law, or a matter on which two views are possible, cannot be treated as a mistake apparent from the record. The question whether the amendment to Rule 29(xii) was merely clarificatory and therefore retrospective was itself a contentious legal issue requiring interpretation and was not an obvious error. Even if the earlier order was legally erroneous, it did not amount to a rectifiable mistake within the narrow ambit of Section 21-A.
Conclusion: The rectification application was not maintainable, and the Tribunal lacked jurisdiction to modify its earlier order on that basis.
Final Conclusion: The writ petition succeeded, the rectification order was set aside, and the original order allowing the dealer's claim was restored.
Ratio Decidendi: Rectification power can be exercised only for an obvious and patent mistake apparent from the record, and not to reopen or revise a debatable issue of law or a prior view on the prospective or retrospective effect of an amendment.