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Issues: Whether the rectification application disclosed any mistake apparent on the face of the record in the Tribunal's earlier order rejecting the refund claim as time-barred.
Analysis: The application sought to re-agitate the merits of the refund dispute by contending that the claim was consequential to an earlier Tribunal order, that the duty had been paid under protest, and that additional evidence ought to have been admitted. These contentions did not disclose any patent error in the earlier order. The questions whether the refund claim was within time, whether the payment was under protest, and whether further documents should have been received were matters decided on facts and discretion, not self-evident mistakes capable of rectification. A rectification jurisdiction cannot be used to recall a final order or to obtain rehearing on debatable issues of fact or law.
Conclusion: No mistake apparent on the face of the record was shown, and the rectification application was not maintainable.