Rectification power cannot be used as review; Tribunal may correct only patent errors apparent on the record.

Rectification under Section 420(2) and Rule 11 is confined to correcting a patent mistake apparent from the record, not to reopening a concluded order. Where the applicant relied on documents filed after the Tribunal-fixed time and the earlier clarification was directed to the applicant company rather than the tax department, no apparent error was shown. The relief sought would have required reconsideration of the merits, which is impermissible under the rectification power. The application was therefore not maintainable and was rightly rejected.

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Issues: Whether the Tribunal could rectify its earlier order under Section 420(2) of the Companies Act, 2013 and Rule 11 of the NCLT Rules, 2016 on the ground of a mistake apparent on the face of the record, or whether the application was in substance an impermissible review.

Analysis: The application sought reconsideration of documents that were filed after the time fixed by the Tribunal. The clarification sought earlier had been directed to the applicant company and not to the Income Tax Department. Since the material relied upon was not produced within the prescribed time, the earlier order disclosed no patent or apparent error warranting rectification. The relief sought would amount to review of the earlier order, but the Tribunal has no jurisdiction to review its own order under the rectification power. The power to correct the record is confined to removal of a clear mistake and cannot be used to reopen a concluded decision.

Conclusion: The application for rectification was not maintainable and was rightly rejected. The decision is against the applicant company and in favour of the respondent.

Ratio Decidendi: Rectification under Section 420(2) is limited to correcting a patent mistake apparent from the record and cannot be invoked to secure a review or reconsideration of a concluded order.

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