Rectification for apparent mistake fails where reassessment merely reflects a change of opinion on the same records.

Rectification under section 61 of the Estate Duty Act is permissible only where there is a mistake apparent from the record. The original estate duty assessment had been made after the accountable person filed the balance-sheet, explained the returned value, and the assessing authority examined the relevant income-tax and wealth-tax records before accepting the declared figure. The later enhancement was therefore not based on any apparent mistake, but on a reassessment of the same material and a mere change of opinion. The invocation of section 61 was accordingly held unjustified, and the rectification order was cancelled.

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Issues: Whether the rectification of the original estate duty assessment under section 61 of the Estate Duty Act was valid.

Analysis: Rectification under section 61 is permissible only where there is a mistake apparent from the record. The original assessment was made after the accountable person filed the balance-sheet, furnished an explanation for the returned value, and the assessing authority examined the relevant records, including the income-tax and wealth-tax files, before accepting the declared figure. On these facts, the later enhancement was not based on an apparent mistake but on a reassessment of the same material, which amounted to a change of opinion.

Conclusion: The invocation of section 61 was not justified and the rectification order was rightly cancelled.

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