Rectification under Rule 19 cannot be used as review, and a filed return may bar advance ruling as pending before the Assessing Officer.

Rule 19 permits only correction of mistakes apparent from the record, so an application that in substance seeks review of an earlier order is not maintainable. The filing of a return of income also means the question of taxability is within the Assessing Officer's domain and is treated as pending for purposes of the proviso to section 245R(2). The cited Handbook and prior rulings did not support any contrary position, and section 153 did not override the statutory bar under section 245R(2). The rectification request was therefore not maintainable, no apparent mistake was shown, and the advance ruling application remained barred.

---

---

Issues: Whether the application for rectification under Rule 19 was maintainable and whether the filing of a return of income meant that the question raised for advance ruling was already pending before the Assessing Officer under the proviso to section 245R(2).

Analysis: The application was in substance an attempt to seek review of the earlier order, while Rule 19 permits only correction of mistakes apparent from the record. On merits, the filing of a return brought the matter within the Assessing Officer's domain because any ruling on taxability would directly affect the assessment. The cited Handbook and prior rulings did not support the proposition that a filed return prevents the question from being treated as pending before the Assessing Officer. Section 153 also did not override the statutory bar in section 245R(2).

Conclusion: The application was not maintainable as a rectification request, no apparent mistake was shown in the earlier order, and the advance ruling application remained barred because the question was already pending before the Assessing Officer.

---