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Issues: Whether the rectification of mistake application disclosed any apparent mistake on the face of the record warranting interference with the Tribunal's earlier order.
Analysis: The application sought to reopen the merits of the earlier decision by challenging the Tribunal's reasoning on the classification of the services and the extent of tax liability. The Tribunal held that rectification cannot be used to pass a fresh order or to reargue the case, and that every sentence or argument need not be reproduced if the cumulative effect of the order is clear. It found that no apparent mistake was shown and that the application was essentially an attempt to seek review under the guise of rectification.
Conclusion: No rectifiable mistake was made out and the application was not maintainable.