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Issues: Whether the Tribunal was justified in invoking rectification powers under Section 43 of the KGST Act to alter its earlier appellate order on the ground that it had not followed the Full Bench decision, even though the issue was debatable and capable of different views.
Analysis: Section 43 permits rectification only of an error apparent on the face of the record. The earlier appellate order had been passed after detailed consideration of the relevant decisions, including the Full Bench ruling, and the Tribunal had consciously taken one possible view on the legal issue. Where the correctness of that view depended on choice between competing judgments and the matter admitted of more than one conclusion, the alleged mistake was not self-evident from the record. Such a debatable question could not be reopened by rectification and, if erroneous, could only be corrected in appropriate revisional proceedings.
Conclusion: The Tribunal had no jurisdiction to pass the rectification order under Section 43 of the KGST Act, and the rectified order was liable to be set aside.
Ratio Decidendi: A question that is debatable or capable of two views does not constitute an error apparent on the face of the record and cannot be corrected in rectification proceedings.