Rectification cannot reopen a debatable issue where identical refund claims are governed by a common appellate determination.

Rectification under the mistake-apparent-from-record jurisdiction is limited to correcting an obvious record error and cannot be used to reopen a debatable issue or substitute for an appeal against an alleged error of judgment. Where three refund claims arose from identical facts and had been decided by a common order later reversed by the High Court, the later judgment could properly govern the remaining identical claims. A grievance that the High Court ruling should not apply to the other claims went to the merits, not to a rectifiable mistake. The rejection of the rectification applications was therefore upheld.

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Issues: Whether the orders rejecting the applications for rectification of mistake were justified, and whether the assessee could invoke rectification to contend that the later High Court judgment, passed in one of the connected refund matters, did not govern the other two identical refund claims.

Analysis: The refund disputes in all three matters arose from identical facts and issues, and the Tribunal had earlier disposed of them by a common order. The High Court subsequently reversed that common order and upheld the adjudicating authority's view. In these circumstances, the adjudicating authority was entitled to take the High Court decision as governing the identical refund claims, even though no separate appeal had been filed in respect of the two smaller claims. Any grievance against that view concerned the merits of the decision and not a mistake apparent from the record. A rectification application cannot be used as a substitute for an appeal or to correct an alleged error of judgment.

Conclusion: The rejection of the rectification applications was valid, and the challenge to the common appellate order failed.

Ratio Decidendi: Rectification is confined to correcting an obvious mistake apparent from the record and cannot be invoked to reopen a debatable issue or substitute for an appeal against an error of judgment, especially where the underlying issues are identical and governed by a common appellate determination.

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