Rectification proceedings cannot revisit debatable legal issues or challenge precedent applicability without a mistake apparent from the record.

A challenge to the applicability of earlier High Court decisions raised a question of law, not a mistake apparent from the record, and could not be entertained in rectification proceedings. The Tribunal also noted that the relevant issues had already been decided afresh in denovo proceedings, including eligibility for exemption under Notification No. 1/2006-ST and Notification No. 6/2005-ST, which further weighed against recalling the final order. No mistake apparent from the record was found, so the rectification applications were dismissed.

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Issues: Whether the rectification of mistake applications disclosed any mistake apparent from the record warranting recall of the final order.

Analysis: The Tribunal held that the challenge to the applicability of the earlier High Court decisions raised a question of law and not a mistake apparent from the record, and therefore could not be examined in rectification proceedings. It also noted that, pursuant to the final order, the relevant matters had already been decided afresh in denovo proceedings, including the appellants' eligibility for exemption under Notification No. 1/2006-ST and Notification No. 6/2005-ST, which further weighed against recalling the order.

Conclusion: No mistake apparent from the record was found, and the rectification of mistake applications were dismissed.

Ratio Decidendi: A debatable legal contention or a challenge to the applicability of precedent does not constitute a mistake apparent from the record and cannot justify recall in rectification proceedings.

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