Rectification cannot reopen a concluded reassessment on merits; the proper remedy lies in revisional jurisdiction.

A completed reassessment cannot be reopened through rectification where the alleged error goes to the merits of the assessment and not to a clerical or apparent mistake. The assessing authority had already considered the department's relied-upon judgment and allowed input tax credit on the facts before it; a later rectification notice seeking to withdraw that credit and revisit the concluded order exceeded rectification powers. The proper course, if the order was considered erroneous and prejudicial to revenue, lay before the revisional authority. The rectification notice was therefore without jurisdiction and was quashed.

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Issues: Whether the assessing authority had jurisdiction to invoke rectification proceedings to reopen the reassessment order and withdraw the input tax credit earlier allowed, on the basis that the reassessment was prejudicial to the interests of revenue.

Analysis: The reassessment had already considered the relevant judgment relied upon by the department and had allowed the input tax credit on the facts placed before the authority. The later notice under the rectification provision sought to revisit that concluded assessment on the footing that the earlier order was erroneous and revenue prejudicial. Such reopening was not within the scope of the rectification power of the assessing authority. If the order was to be challenged on that basis, the appropriate course lay before the revisional authority and not by invoking rectification to unsettle the reassessment.

Conclusion: The rectification notice was without jurisdiction and was quashed, in favour of the assessee.

Final Conclusion: The attempt to reopen the reassessment through rectification was invalid, and the assessee obtained relief against the impugned notice, while leaving liberty for the department to proceed in accordance with law.

Ratio Decidendi: A completed reassessment cannot be reopened through rectification when the alleged error relates to the merits of the assessment and the proper remedy lies in the statutory revisional jurisdiction.

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