Rectification under tax law cannot reopen a concluded revisional order on merits or replace the statutory remedy.

Section 71 of the Madhya Pradesh Commercial Tax Act permits only rectification of clerical or arithmetical mistakes, or errors arising from accidental slip or omission; it cannot be used to reopen a revisional order on merits or seek a rehearing. The revisional authority had considered the material and rejected it on factual grounds, and no perversity in those findings was shown. In writ jurisdiction under Article 226, the High Court will not act as an appellate forum over such factual determinations. The rectification application was therefore outside the scope of section 71, and no interference with the revisional order was warranted.

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Issues: Whether an application under section 71 of the Madhya Pradesh Commercial Tax Act could be used to recall or reopen a revisional order on merits, and whether the High Court should interfere with the revisional findings in writ jurisdiction.

Analysis: Section 71 permits rectification only for correcting clerical or arithmetical mistakes or errors arising from accidental slip or omission. The provision does not authorise a dealer to seek a rehearing on merits, recall of a concluded revisional order, or substitution of the statutory remedy by way of rectification. The revisional authority had examined the material produced and rejected it on factual grounds, and no perversity in those findings was shown. In writ jurisdiction under Article 226 of the Constitution of India, the Court does not sit as an appellate authority over such factual determinations.

Conclusion: The rectification application was outside the scope of section 71, and the revisional order did not warrant interference.

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