Rectification powers under income-tax law cannot be used to review or recall an appellate order on alleged record mistakes.

Section 254(2) permits only rectification of mistakes apparent from the record; it does not authorise reopening the appeal, rearguing the merits, or substituting a fresh decision under the guise of correction. A recall of the earlier appellate order would require rehearing and re-adjudication, which is beyond the Tribunal's limited rectification power because no express power of review exists. On that basis, a request framed as an error in appreciating a chart and duplicate entries was treated as an impermissible attempt to seek review rather than correction of an apparent mistake, and the miscellaneous applications were rejected.

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Issues: Whether, in proceedings under section 254(2) of the Income-tax Act, 1961, the Tribunal could recall or review its earlier appellate order on the ground of an alleged mistake in appreciating the chart and duplicate entries.

Analysis: The Tribunal held that its jurisdiction under section 254(2) is confined to rectifying mistakes apparent from the record. It cannot be used to reopen the entire appeal, reargue the merits, or substitute a fresh decision under the guise of rectification. The power to rectify is not a power of review, and no express power of review is conferred on the Tribunal. A recall of the order would necessarily entail rehearing and re-adjudication of the appeal, which is beyond the limited scope of section 254(2). The alleged grievance raised by the Revenue was thus treated as an attempt to seek review of the earlier decision rather than correction of any apparent mistake.

Conclusion: The Tribunal had no power to recall or review its earlier order under section 254(2), and the miscellaneous applications filed by the Revenue were rejected.

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