Rectification power confined to apparent errors; assessment cannot be reopened to re-examine concluded transactions.

The rectification power under Section 69 of the Karnataka Value Added Tax Act, 2003 is limited to correcting mistakes apparent from the record and cannot be used to reopen concluded factual findings, re-examine individual transactions, or seek review of an assessment order. A request to scrutinise each transaction afresh falls outside rectification and is not maintainable once the assessing authority has become functus officio, save for the narrow statutory exception. Earlier appellate directions relating to another assessment year were held not automatically applicable to the present proceedings. The rectification application therefore failed, and no interference with the impugned order or endorsement was warranted.

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Issues: Whether the rectification power under Section 69 of the Karnataka Value Added Tax Act, 2003 could be invoked to require re-examination of individual transactions and to challenge the assessment order and endorsement impugned.

Analysis: Section 69 permits amendment only to rectify a mistake apparent from the record. The expression cannot be stretched to reopen, re-analyse, or revisit concluded factual issues decided in assessment. A request to scrutinise each transaction afresh falls outside the statutory ambit of rectification and amounts to seeking a review, which is not permissible. The earlier appellate directions in a different assessment year were held to be specific to that year and not automatically applicable to the present proceedings. Once the assessment order is passed, the assessing authority becomes functus officio save to the limited extent provided by Section 69.

Conclusion: The rectification application was not maintainable for the relief sought, and no ground was made out to interfere with the impugned order and endorsement.

Ratio Decidendi: The power of rectification under Section 69 of the Karnataka Value Added Tax Act, 2003 is confined to correcting mistakes apparent from the record and cannot be used to reopen concluded factual findings or seek a review of the assessment.

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