Rectification review cannot reopen a factual and legal finding allowing refund for completed exports absent an apparent mistake.

Rectification was refused because the Revenue failed to identify any apparent mistake in the Tribunal's final order. The Tribunal had already determined, on the facts and law, that refund was maintainable for exports already made, and that conclusion could not be reopened in rectification proceedings merely by alleging factual or legal error. In the absence of a specific error requiring correction, the order stood and the Revenue's application was rejected.

---

---

Issues: Whether the Revenue had shown any apparent mistake in the final order so as to justify rectification, and whether the finding that refund was permissible in respect of exports already made could be disturbed in rectification proceedings.

Analysis: The Tribunal noted that the earlier final order had reached its conclusion on appreciation of the facts and had held that the refund claim was maintainable in respect of the exports made by the appellant. It further observed that such a factual and legal conclusion could not be reopened merely on the assertion that it was contrary to the facts or the law, especially when the Revenue had not pointed out any specific mistake in the order requiring correction.

Conclusion: No ground for rectification was made out, and the Revenue's application was rejected.

---