Rectification cannot reopen decided issues on precedent and limitation; no apparent mistake was shown, so the application failed.

A rectification application cannot be used to reopen findings already recorded on precedent or limitation, because that would amount to an impermissible review of the order. The Tribunal noted that its earlier decision had already given reasons for distinguishing the cited precedent and for rejecting the limitation plea, including the absence of disclosure of endorsed invoices and the audit-based detection of irregular Cenvat credit availment. As no apparent mistake on the face of the record was shown, no rectifiable error was established and the application was rejected.

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Issues: Whether the Tribunal could entertain a rectification application to reconsider its earlier findings on applicability of precedent and limitation, and whether any apparent mistake warranting correction was shown.

Analysis: The application sought correction of the final order on the ground that an earlier Tribunal decision had not been followed and that the finding on limitation was erroneous. The Tribunal noted that the earlier order had already recorded reasons for distinguishing the cited precedent and for rejecting the limitation plea, including the absence of disclosure of endorsed invoices and the detection of irregular availment of Cenvat credit during audit verification. A rectification proceeding cannot be used to reopen or re-argue issues already decided, since that would amount to review of the order. The Tribunal also reiterated that it has no power to review its own order.

Conclusion: No rectifiable mistake was established and the application was rejected.

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