Rectification cannot be used for substantive review when a Tribunal seeks to reverse a clear, reasoned order.

A rectification power cannot be used to rewrite a reasoned Tribunal order on the merits by treating a change in outcome as a mere typographical error. Where the original conclusion is clear and unambiguous, only a genuine clerical or apparent mistake may be corrected; a substantive reversal amounts to an impermissible review. The High Court therefore held that the Tribunal exceeded the scope of rectification in modifying its earlier decision and set aside the rectification order.

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Issues: Whether the Tribunal was justified in recalling and modifying its earlier order on a rectification application on the ground of an apparent typographical error.

Analysis: The original order of the Tribunal was a reasoned decision on the merits of the Revenue's appeal and its conclusion was unambiguous. The alleged mistake did not disclose a simple clerical or typographical slip capable of correction through rectification. Rewriting the conclusion from one outcome to the opposite amounted to a substantive review of the merits, which was beyond the scope of rectification.

Conclusion: The rectification order was not sustainable and was set aside. The Tribunal erred in reversing its earlier decision under the guise of correcting an apparent mistake.

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