Rectification power under GST law cannot reopen merits or rewrite appellate orders absent an apparent error on record.

Section 161 of the West Bengal GST Act is confined to rectifying patent errors apparent from the record and cannot be used to recall, rewrite, or materially alter an appellate order. By analogy to Order 47 Rule 1 and section 152 of the Code of Civil Procedure, rectification is not an appeal in disguise and does not permit reappreciation of merits or substitution of a fresh decision. As no self-evident error was shown in the earlier appellate order, the later rectification application exceeded statutory power and was without jurisdiction. The earlier appellate order was restored and registration reinstatement followed.

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Issues: Whether the rectification power under section 161 of the West Bengal Goods and Services Tax Act could be used to recall, rewrite, or materially alter an earlier appellate order in the absence of an error apparent on the face of the record.

Analysis: Section 161 is treated as a rectification provision akin to Order 47 Rule 1 of the Code of Civil Procedure and, by analogy, section 152 of the Code of Civil Procedure. The power is confined to correcting patent errors apparent from the record and cannot be used for long-drawn reasoning, reappreciation of the merits, or substitution of a fresh decision. A review or rectification jurisdiction is not an appeal in disguise. On the admitted facts, the later application did not identify any self-evident error in the earlier appellate order and instead sought to reopen the entire controversy and alter the result. That course lay beyond the statutory power.

Conclusion: The rectification order was without jurisdiction and could not stand; the earlier appellate order was restored and the assessee was entitled to reinstatement of registration.

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