Rectification under section 254(2) cannot be used to review earlier findings or reopen merits without a patent record error.

Section 254(2) permits only correction of a mistake apparent from the record and does not allow reappraisal of facts or review of an earlier order. The miscellaneous applications sought reconsideration of findings already recorded in the Tribunal's common order dated 03.10.2017, but no patent error was shown on the face of the record. The Tribunal therefore treated the applications as an impermissible attempt to reopen the merits and dismissed them for want of any rectifiable mistake.

---

---

Issues: Whether the assessee had demonstrated any mistake apparent from the record warranting rectification of the Tribunal's earlier order under section 254(2) of the Income-tax Act, 1961, and whether the miscellaneous applications were in substance an impermissible attempt to seek review of that order.

Analysis: Rectification under section 254(2) is confined to patent mistakes apparent from the record and does not confer a power to revisit, reappraise, or review the merits of the earlier decision. The grounds raised in the miscellaneous applications sought reconsideration of findings already returned by the Tribunal on appreciation of facts and law in the common order dated 03.10.2017. No error apparent from the record was shown, and the applications in substance invited a fresh examination of conclusions already reached.

Conclusion: The Tribunal held that no rectifiable mistake was made out and rejected the attempt to reopen the earlier merits decision; the miscellaneous applications were dismissed.

---