Rectificatory jurisdiction cannot reopen a concluded order or admit fresh evidence after limitation in revival matters.

A rectificatory application under Section 420(2) of the Companies Act could not be used to reopen a concluded order or introduce fresh evidence after the statutory period had expired, so the belated request for amendment and reconsideration of revival was rejected. Additional documents were also refused because the applicant had not shown due diligence in producing them earlier, and permission to seek amendment did not extend to filling gaps in the original case. The High Court's liberty to seek revival was confined to the permissible procedural course and did not enlarge the substantive relief available. The appeal therefore failed.

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Issues: (i) Whether the application seeking amendment, reception of additional documents and reconsideration of revival was maintainable after the expiry of the statutory period under Section 420(2) of the Companies Act, 2013. (ii) Whether the appellant was entitled to rely on additional documents and the High Court's liberty to seek revival of the struck-off company.

Issue (i): Whether the application seeking amendment, reception of additional documents and reconsideration of revival was maintainable after the expiry of the statutory period under Section 420(2) of the Companies Act, 2013.

Analysis: The power of the Tribunal to amend an order is confined to rectifying a mistake apparent from the record and cannot be used to reopen a concluded matter or to introduce a fresh case by way of additional evidence. The application was filed beyond the prescribed two-year period from the original dismissal order, and the relief sought was not a true amendment but an attempt to secure substantive reconsideration of revival. Such belated invocation of the rectificatory jurisdiction was not permissible.

Conclusion: The issue was decided against the appellant; the application was not maintainable in view of limitation and the restricted scope of Section 420.

Issue (ii): Whether the appellant was entitled to rely on additional documents and the High Court's liberty to seek revival of the struck-off company.

Analysis: Permission to seek amendment did not extend to filing additional evidence to fill gaps in the earlier case. The Tribunal found that the appellant had not shown due diligence for producing the material earlier, and additional documents could not be received merely because they might support the appellant's case. The liberty granted by the High Court was confined to the permissible procedural course and did not authorise enlargement of the original relief beyond that scope.

Conclusion: The issue was decided against the appellant; the additional documents were not liable to be received and revival could not be reconsidered on that basis.

Final Conclusion: The appeal failed because the impugned order rejecting the belated request for amendment, additional evidence and revival disclosed no legal infirmity.

Ratio Decidendi: A rectificatory power cannot be used to reopen a concluded order or to introduce additional evidence after limitation, and a party cannot expand a limited procedural liberty into a fresh substantive claim for revival.

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