Rectification under section 254(2) cannot be used to recall an order or reopen merits already decided.

Section 254(2) confines the Tribunal's power to rectifying mistakes apparent from the record and does not permit recall, review, or a rehearing on merits. Because the earlier order had already considered the assessee's submissions and decided the issue, a miscellaneous application seeking to reopen the same controversy was treated as an impermissible attempt to re-argue the case. The Tribunal had no inherent power of review unless expressly conferred, so the earlier order could not be recalled in its entirety. The miscellaneous application was therefore liable to be rejected.

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Issues: Whether the Tribunal could recall or re-adjudicate its earlier order under section 254(2) of the Income-tax Act, 1961 on the ground that the assessee sought to re-argue the merits of the addition sustained in the assessment.

Analysis: The scope of section 254(2) is confined to rectification of mistakes apparent from the record. Recalling an order in its entirety would amount to a fresh hearing and a review on merits, which is impermissible because the Tribunal has no inherent power of review unless expressly conferred. The earlier order had already considered the assessee's contentions and decided the issue; the miscellaneous petition merely attempted to reopen the same controversy.

Conclusion: The Tribunal had no power to recall or reopen the earlier order under section 254(2), and the miscellaneous application was liable to be rejected.

Ratio Decidendi: Section 254(2) permits only correction of a mistake apparent from the record and does not authorise recall, review, or rehearing of an order on merits.

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