Rectification of apparent error under tax law is wider than clerical mistakes and requires merits-based reconsideration.

Section 84 of the Tamil Nadu Value Added Tax Act, 2006 empowers rectification of any error apparent on the face of the record and is not limited to clerical or arithmetical mistakes. An error is rectifiable where it is obvious from the record and does not require a long process of reasoning or debate; an order contrary to the statute, binding precedent, or material facts or law may satisfy that standard. The authority rejected the rectification petitions on an unduly narrow view of its power without examining whether such an apparent error existed. The rejection was unsustainable, and the matter had to be reconsidered on merits under Section 84.

---

---

Issues: Whether the authority under Section 84 of the Tamil Nadu Value Added Tax Act, 2006 was justified in rejecting the rectification petitions on the ground that only clerical and arithmetical mistakes could be corrected, and whether the impugned orders disclosed an error apparent on the face of the record.

Analysis: Section 84 confers power to rectify any error apparent on the face of the record and is not confined to clerical or arithmetical mistakes. A mistake is rectifiable when it is obvious from the record and does not require a long drawn process of reasoning or debate. An order contrary to the statute or binding precedents, or one that fails to consider relevant factual or legal material, may disclose such an error. The authority did not examine the petitions on that basis and instead rejected them on an unduly narrow understanding of its power.

Conclusion: The rejection of the rectification petitions was unsustainable, and the matter had to be reconsidered on merits under Section 84.

---