Rectification jurisdiction is limited to apparent errors, not merits review, and writ interference was declined for lack of procedural breach.

Rectification under section 66 of the Kerala Value Added Tax Act is confined to self-evident errors apparent on the face of the record and does not extend to debatable questions, reassessment of facts, or a disguised rehearing on the merits. A rectification order will not attract Article 226 interference where the authority has addressed the grounds raised and no clear jurisdictional or procedural error is shown. Natural justice concerns arise only where the statute requires a hearing, such as when rectification may enhance assessment or penalty; on the facts stated, no hearing was sought in the rectification application. The availability of an alternative statutory remedy further weighs against writ intervention.

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Issues: Whether the order rejecting rectification under section 66 of the Kerala Value Added Tax Act, 2003 was liable to be interfered with under Article 226 of the Constitution of India on the grounds that the alleged mistakes were apparent on the face of the record and that there was violation of natural justice.

Analysis: The scope of rectification under section 66 is confined to errors apparent on the face of the record. Such an error must be self-evident and not one that requires elaborate argument, investigation, or a long drawn process of reasoning. Debatable issues, alleged perversity in appreciation of facts, and challenges that in substance seek a rehearing do not fall within rectification jurisdiction. The rectification order was not cryptic and had dealt with the grounds raised. As to natural justice, the statutory requirement of hearing applies where rectification may enhance assessment or penalty, and the petitioner had not sought a hearing in the rectification application. The existence of an alternative statutory remedy also weighed against interference in writ jurisdiction.

Conclusion: The rectification order did not disclose any error warranting interference under Article 226, and there was no violation of natural justice on the facts presented.

Final Conclusion: The writ court declined to substitute its view for the statutory authority's decision and left the petitioner to pursue the available statutory remedy.

Ratio Decidendi: Rectification can be invoked only for a self-evident error apparent on the face of the record, not for issues requiring detailed reasoning or reconsideration of the merits, and writ interference is unwarranted where the authority has considered the grounds and no hearing was sought in circumstances where the statute did not require one.

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