Rectification cannot become review when merger has already settled the issue and detailed reasoning is required.

A rectification application before the Tribunal was found not maintainable where the correctness of the earlier order had already been considered in connected proceedings and the doctrine of merger applied. The court held that grounds requiring long-drawn reasoning go beyond the limited scope of rectification and amount in substance to a review, which the Tribunal cannot undertake under the guise of correcting a mistake. The Tribunal therefore lacked jurisdiction to entertain the application, and rejection of rectification was sustained in favour of the Revenue.

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Issues: Whether the Tribunal could entertain the rectification application and whether the grounds urged in it amounted to an impermissible review rather than a rectification of mistake.

Analysis: The rectification application was held to be not maintainable because the correctness of the Tribunal's earlier order had already been considered in connected proceedings and the doctrine of merger applied. The Court further held that the grounds raised in the application required long-drawn reasoning, which is beyond the permissible scope of rectification proceedings and amounts in substance to a review.

Conclusion: The Tribunal had no jurisdiction to entertain the rectification application, and the rejection of the application was upheld.

Final Conclusion: The appeal failed and the Tribunal's order rejecting rectification was sustained, with the issue answered in favour of the Revenue.

Ratio Decidendi: A rectification application cannot be used to reopen an issue already concluded by merger or to undertake a review-like examination requiring detailed reasoning.

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