Rectification of final estate duty assessment fails absent a manifest error apparent from the record.

Section 61 of the Estate Duty Act permits rectification only where a manifest mistake apparent from the record is shown. Where the heirs had accepted the principal accountable person's return, the assessment was completed on that basis, the duty had been paid, and the assessment had long attained finality, rectification could not be used to reopen the basis of liability or the computation. A belated challenge rooted in a family dispute and not in any patent record error fell outside the scope of rectification, so the application was not maintainable and the assessment remained undisturbed.

---

---

Issues: Whether the appellant could invoke section 61 of the Estate Duty Act to rectify the completed estate duty assessment on the ground of an apparent mistake in the treatment of the controlled company and the computation of duty.

Analysis: The heirs other than the accountable person who filed the return had agreed to abide by the accounts rendered by the principal accountable person, and the assessment was completed on that basis without objection. The assessment had attained finality long before the rectification request was made, the duty had already been paid, and the challenge sought to reopen the basis of liability and computation rather than point to a patent error on the face of the record. On the facts, no mistake apparent from the record was shown, and the controversy was essentially a private family dispute, which did not justify use of the rectification power.

Conclusion: The application under section 61 was not maintainable, and the refusal to rectify the assessment was in law; the challenge failed.

Final Conclusion: The concluded estate duty assessment could not be reopened through rectification, and the dismissal of the appeals left the assessment undisturbed.

Ratio Decidendi: A completed assessment cannot be reopened under the rectification power unless a manifest mistake apparent from the record is shown; a belated attempt to dispute the basis of liability or computation after acquiescence and finality is not a permissible use of rectification.

---