Rectification under section 254(2) is limited to apparent errors and cannot be used to reargue merits or revisit conclusions.

Section 254(2) permits rectification only of a mistake apparent from the record and does not allow a rehearing on the merits or reconsideration of conclusions already reached. A petition that merely reargues treaty benefit entitlement and the validity of the draft assessment order, without identifying any patent error in the earlier order, falls outside that limited scope. The rectification request was therefore not maintainable on the grounds advanced and was dismissed.

---

---

Issues: Whether the rectification petition disclosed any mistake apparent from the record within the limited scope of section 254(2) so as to warrant interference with the earlier order.

Analysis: The application sought reconsideration of arguments on the merits of the earlier decision, including the assessee's entitlement to treaty benefit and the validity of the draft assessment order. Such contentions did not point out any patent error in the order sought to be rectified. The scope of section 254(2) is confined to correcting an apparent mistake and does not permit a rehearing on merits or a revisit to conclusions already reached.

Conclusion: The rectification petition was not maintainable on the grounds urged and was dismissed.

---