Rectification cannot reopen disputed tax rate issues; a notice seeking reassessment of earlier tax treatment exceeded limited jurisdiction.

Rectification under Section 31 of the U.P. Value Added Tax Act, 2008 is limited to mistakes apparent from the record, meaning patent errors that do not require debate, investigation, or fresh adjudication. A reassessment of the applicable entry or tax rate, or a change in the assessing authority's earlier view on those questions, falls outside rectification because it effectively reopens the assessment on a disputed issue. On the stated facts, the notice sought to revisit the earlier tax treatment and was therefore beyond the scope of Section 31 and could not be sustained.

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Issues: Whether a notice issued under Section 31 of the U.P. Value Added Tax Act, 2008 could be sustained as a rectification proceeding when the dispute concern the applicable rate of tax and was, in substance, a case of escaped assessment.

Analysis: Rectification jurisdiction is confined to a mistake apparent from the record, meaning an error that is patent, obvious, and not dependent on elaborate argument, investigation, or a debatable question of law or fact. A change in the view taken by the assessing authority on the applicable entry and rate of tax does not amount to correction of an apparent mistake; it amounts to re-examination of the assessment on a matter requiring adjudication. On the facts, the impugned notice sought to reopen the tax treatment adopted earlier, which could not be brought within the limited scope of Section 31.

Conclusion: The notice under Section 31 was jurisdiction and could not be sustained; the challenge succeeded.

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