Rectification cannot reopen final reassessment; second appeal is confined to mistakes apparent from the record.

A second appellate authority cannot use rectification proceedings to reopen a reassessment order that has attained finality. The rectification application was limited to alleged mistakes apparent from the record, and the first appellate authority had already found no such mistake. In second appeal, the Tribunal was required to test only the correctness of the order refusing rectification; it could not expand the dispute, reassess evidence, or examine issues such as seized documents or turnover discrepancies that fell outside rectification. Those grievances could be raised only in a regular appeal. The Tribunal's remand was therefore impermissible and the issue was answered against the assessee.

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Issues: Whether the Second Appellate Authority could remand the matter by travelling beyond the grounds raised in the rectification proceedings and reopening a reassessment order that had attained finality.

Analysis: The reassessment order had not been challenged in regular appeal and had attained finality. The rectification application was confined to alleged mistakes apparent from the record, and the First Appellate Authority had already held that no such mistake was shown. In second appeal, the Tribunal was bound to examine only the correctness of the order rejecting rectification. It could not expand the controversy, reassess the evidence, or reopen the reassessment on issues such as the nature of seized documents or alleged turnover discrepancies, as those matters went beyond the narrow scope of rectification. Any such grievance could be pursued only in a regular appeal and not through rectification proceedings.

Conclusion: The remand ordered by the Tribunal was impermissible and the issue was rightly answered against the assessee.

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