Rectification jurisdiction cannot reopen factual findings or debatable legal issues; only apparent record errors may be corrected.

Rectification jurisdiction is confined to correcting an apparent mistake on the face of the record and cannot be used to reassess factual findings or revisit debatable legal issues. The Tribunal noted that the earlier order had already recorded detailed findings on use of capital goods in manufacturing exempted goods, distinguished the cited precedents on facts, and treated the assessee's declaration as mis-declaration. Those objections involved factual appraisal and arguable legal conclusions, not patent clerical errors. The rectification request was therefore rejected because no mistake apparent from the record was established.

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Issues: Whether the order suffered from a mistake apparent on the face of the record so as to warrant rectification, and whether the Tribunal could reassess the factual findings and legal conclusions in the guise of rectification.

Analysis: The application sought correction of findings on use of capital goods, appreciation of case law, and limitation. The Tribunal held that the earlier order had recorded detailed findings that the capital goods were used in manufacturing exempted goods, that the cited precedents were distinguished on facts, and that the declaration filed by the assessee amounted to mis-declaration. These were not obvious clerical or patent errors but matters involving factual appraisal and debatable legal issues. A rectification jurisdiction cannot be used to reargue the merits or substitute a different view, and the power available is confined to correcting an apparent mistake, not reviewing the prior order.

Conclusion: No mistake apparent from the record was established and the rectification request was rejected.

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