Rectification application held infructuous after exemption dispute was finally resolved in favour of the assessee

A rectification application does not survive where the substantive exemption dispute has already been finally decided in favour of the assessee and no independent error apparent on the face of the record remains. With the principal controversy over eligibility for the exemption notifications settled by the Supreme Court, the alternative grounds raised for rectification lost practical relevance. The application was therefore treated as infructuous and not fit for consideration.

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Issues: Whether the rectification application survived after the principal dispute regarding exemption on the final product had already been finally decided in favour of the assessee.

Analysis: The principal controversy regarding eligibility of the final product to the relevant exemption notifications had already been settled by the Supreme Court in favour of the assessee. Once that substantive controversy stood concluded, the alternative grounds urged in support of rectification ceased to have practical relevance. The application therefore no longer disclosed any surviving error apparent on the face of the record requiring correction.

Conclusion: The rectification application was held to be infructuous and not fit for consideration.

Ratio Decidendi: A rectification application does not survive when the substantive issue underlying the order has already been finally resolved in favour of the applicant and no independent mistake affecting the operative result remains.

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