Mistake apparent on the record requires a manifest error; inconclusive documents cannot justify rectification.

Rectification was refused because no mistake apparent on the record was shown. The Tribunal held that the bank letter and FIRC-related clarification did not clearly confirm receipt of remittance in convertible foreign exchange, and the earlier order had already proceeded on that absence of clear confirmation. A disputed factual assertion or an inconclusive document could not establish a patent or obvious error. The original determination therefore remained undisturbed.

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Issues: Whether the order dated 16.02.2017 suffered from a mistake apparent on the record warranting rectification.

Analysis: The application sought rectification on the basis that the assessee had produced a bank letter and FIRC-related clarification. The Tribunal examined the earlier findings and the banker's letter, and found that the letter did not give a clear confirmation that the remittance was received in convertible foreign exchange. Since the earlier order had proceeded on the absence of such clear confirmation, no patent or obvious error was shown on the face of the record.

Conclusion: No mistake apparent on the record was made out, and rectification was not warranted.

Final Conclusion: The rectification request failed, and the original determination was left undisturbed.

Ratio Decidendi: Rectification is impermissible unless the alleged error is manifest and apparent from the record; a disputed factual assertion or an inconclusive document does not constitute such an error.

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