Rectification jurisdiction is limited to apparent mistakes and cannot be used to review or recall a concluded Tribunal order.

Section 254(2) permits only rectification of a mistake apparent from the record and does not authorise review, recall, or rehearing on merits. A party's complaint that the Tribunal did not address every argument or authority in the desired manner does not, by itself, show an apparent mistake. The Tribunal had already consciously decided the issue of valid service of notice under section 148, so the miscellaneous applications were in substance an attempt to reopen a concluded matter. The rectification applications were therefore not maintainable, and the earlier finding on service of notice remained undisturbed.

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Issues: Whether the miscellaneous applications under section 254(2) seeking rectification and recall of the Tribunal's earlier order, which had upheld valid service of notice under section 148, disclosed any mistake apparent from the record.

Analysis: The scope of section 254(2) is confined to rectification of mistakes apparent from the record. It does not confer a power of review or permit the Tribunal to recall its entire order and re-adjudicate the appeal on merits. A grievance that the order did not deal with every argument or authority in the manner desired does not, by itself, establish an apparent mistake. The Tribunal had already considered the material and taken a conscious view on valid service of notice, and the applications in substance sought reopening of the concluded issue, which lies outside the rectification jurisdiction. The power of recall is not available under section 254(2), and an ex parte recall situation under Rule 24 of the ITAT Rules, 1963 was not in issue.

Conclusion: No mistake apparent from the record was shown, and the applications under section 254(2) were not maintainable in substance.

Final Conclusion: The Tribunal's earlier finding on service of notice remained undisturbed, and the assessees' attempt to reopen the merits through rectification failed.

Ratio Decidendi: Section 254(2) permits only rectification of an apparent mistake and cannot be used to review, recall, or rehear an order on merits.

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