Rectification cannot reopen issues already decided on merits; a prior consideration of withdrawal of approval defeated the Revenue's application.

Rectification proceedings cannot be used to reargue a matter already considered on merits, and a mistake apparent from the record must be obvious without any reappraisal of the earlier decision. The Tribunal had already taken note of the retrospective withdrawal of approval to the donee institution while deciding the weighted deduction claim, so the Revenue's miscellaneous application was treated as an impermissible attempt to seek review. The application was held not maintainable and rejected, with only the assessment year reference corrected by corrigendum.

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Issues: Whether the Revenue's miscellaneous application alleging a mistake apparent from the record could be entertained where the withdrawal of approval of the donee institution had already been taken note of in the earlier order.

Analysis: The asserted error did not disclose any apparent mistake in the Tribunal's earlier order because the relevant fact regarding retrospective withdrawal of approval to the institution was already considered while adjudicating the assessee's claim for weighted deduction. The application, in substance, sought reappreciation of the issue and review of the earlier decision, which is impermissible in rectification proceedings.

Conclusion: The miscellaneous application was not maintainable and was rejected.

Final Conclusion: The Revenue obtained no rectification relief, and the earlier order remained undisturbed; the corrigendum only corrected the assessment year reference.

Ratio Decidendi: Rectification cannot be used to reargue a matter already considered on merits, and a mistake apparent from the record must be obvious without requiring review or reappraisal.

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