Rectification of apparent error allows correction of mistaken Cenvat credit figures, but not reopening a concluded merits finding.

Rectification jurisdiction extends to correcting an obvious typographical or apparent factual error in the operative part of an order, so the mismatch in the Cenvat credit figures disallowed on account of inadmissible documents was modified. However, that power does not permit reopening a concluded merits determination: no apparent error was shown in the finding allowing Cenvat credit on the basis that the goods were used in fabrication of capital goods and satisfied the governing credit provision. The applications therefore succeeded only to the limited extent of correcting the mistaken credit amounts and corresponding paragraphs, while the substantive allowance of credit remained undisturbed.

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Issues: (i) Whether the final order required rectification to correct the typographical error in the amounts relating to Cenvat credit disallowed on account of inadmissible documents. (ii) Whether there was any apparent mistake in the final order insofar as it allowed Cenvat credit on the ground of ineligibility of inputs or capital goods.

Issue (i): Whether the final order required rectification to correct the typographical error in the amounts relating to Cenvat credit disallowed on account of inadmissible documents.

Analysis: The record showed that the amounts mentioned in the operative portion of the final order did not correctly reflect the credits actually disallowed in the two appeals. The mismatch was confined to the figures stated for re-adjudication after verification of documents. This was a clear apparent mistake capable of correction in rectification proceedings.

Conclusion: The mistake in the amounts was rectifiable, and the relevant paragraphs of the final order were modified accordingly.

Issue (ii): Whether there was any apparent mistake in the final order insofar as it allowed Cenvat credit on the ground of ineligibility of inputs or capital goods.

Analysis: The final order had already considered the verification report and held that the goods were used in fabrication of capital goods and satisfied the requirement under the then governing credit provision. The present applications sought a reconsideration of that substantive finding, but no error apparent on the face of the record was shown in the allowance of credit on the ineligibility issue.

Conclusion: No rectification was warranted on the merits-based allowance of Cenvat credit for ineligible-inputs or capital-goods objections.

Final Conclusion: The rectification applications succeeded only to the limited extent of correcting the mistaken credit figures and corresponding paragraphs, while the substantive conclusion allowing credit on the ineligibility issue remained undisturbed.

Ratio Decidendi: Rectification jurisdiction extends to correcting an obvious typographical or apparent factual error in the operative part of an order, but it cannot be used to reopen or alter a concluded merits determination.

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