Rectification power cannot be used as a review; a fresh appraisal of evidence falls outside the limited statutory scope.

Rectification is limited to correcting a mistake apparent from the record and does not permit a review or fresh appraisal of the evidence. A patent, obvious error may be corrected, but an issue requiring reconsideration of material or a different view on the same facts lies outside rectification. On that basis, the Tax Board could not reopen its earlier order in the guise of rectification, and the later rectification order was liable to be set aside.

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Issues: Whether the Tax Board could, in the guise of rectification, reopen and alter its earlier order by re-appreciating the material and reaching a different conclusion.

Analysis: The power of rectification under the governing provision is confined to correcting a mistake apparent from the record. Such power does not authorise a review of the earlier decision or a fresh appraisal of the evidence. A mistake that is not obvious and patent, and which requires reasoning or reconsideration of material, falls outside rectification. Where the later order merely substitutes a different view on the same facts and record, it amounts to an impermissible review.

Conclusion: The Tax Board was not justified in changing its earlier order under the garb of rectification, and the impugned rectification order was liable to be set aside.

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