Rectification limited to patent mistakes apparent from the record; debatable legal or factual questions cannot be reopened.

Section 22 of the Uttar Pradesh Sales Tax Act, 1948 permits rectification only of a patent mistake apparent from the record; it cannot be used to revise, review, or substitute the original order. A debatable point of law or a disputed question of fact falls outside that power because it would require detailed reasoning or investigation. Applying that standard, the attempted correction based on an inferential application of earlier authority to aluminium powder was not an error apparent on the face of the record. Rectification was therefore impermissible, and the assessee succeeded on this issue.

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Issues: Whether rectification under Section 22 of the Uttar Pradesh Sales Tax Act, 1948 could be invoked in respect of a debatable issue or only for a mistake apparent from the record.

Analysis: Section 22 permits rectification only of a mistake that is patent, obvious, and self-evident from the record. A power of rectification cannot be used to revise, review, or substitute the original order, and it does not extend to questions requiring elaborate argument, investigation, or a long process of reasoning. A decision on a debatable point of law or on a disputed question of fact is outside the scope of that provision. On the facts, the attempted correction proceeded by inferentially applying earlier authority to aluminium powder and therefore did not involve an error apparent on the face of the record.

Conclusion: Rectification under Section 22 was not permissible, and the assessee succeeded on this issue.

Ratio Decidendi: Rectification is confined to patent mistakes apparent from the record and cannot be used to reopen or substitute an order on a debatable legal or factual question.

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