Rectification jurisdiction limited to apparent record errors; substantive refund relief cannot be reopened after finality.

Rectification jurisdiction is confined to correcting mistakes apparent on the record, and the Tribunal accepted correction of two such errors in the earlier order, including an inaccurate case extract and an incorrect description of a reverse charge payment. The corrected paragraphs were directed to be read in place of the original text. However, the Tribunal held that this jurisdiction could not be used to reopen the final order or grant fresh refund relief after the order had attained finality. The request for substantive modification was therefore rejected, and only clerical and descriptive corrections were allowed.

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Issues: (i) whether the final order contained mistakes apparent on the record warranting rectification; (ii) whether the order could be modified to grant refund relief at the rectification stage after it had attained finality.

Issue (i): whether the final order contained mistakes apparent on the record warranting rectification.

Analysis: The Tribunal found that two apparent mistakes had crept into the earlier order, one in the extract reproduced from the cited case and another in the description of the payment made under reverse charge mechanism. The relevant paragraphs were directed to be read in the corrected form.

Conclusion: The existence of mistakes apparent on the record was accepted and the order was corrected accordingly.

Issue (ii): whether the order could be modified to grant refund relief at the rectification stage after it had attained finality.

Analysis: The Tribunal held that the request for modification could not be entertained at that stage because the final order had already attained finality. Rectification was confined to correcting the apparent mistakes and could not be used to reopen the substantive relief sought.

Conclusion: The request for modification and grant of refund relief was rejected.

Final Conclusion: The rectification application succeeded only to the limited extent of correcting clerical and descriptive errors, but no substantive modification of the final order was permitted.

Ratio Decidendi: Rectification jurisdiction is confined to correction of mistakes apparent on the record and cannot be invoked to alter a final order on merits after it has attained finality.

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