Functus officio bars a post-order corrigendum that enhances duty and adds penalty or interest after adjudication.

After an adjudication order is signed, the authority becomes functus officio and cannot use a corrigendum to substantively alter the operative part by enhancing duty or introducing penalty and interest. Such a post-signature change is not a clerical correction or an error apparent on the face of the record; it amounts to an impermissible review of the adjudication order. The corrigendum was therefore invalid and unsustainable in law, and the Revenue's appeal failed.

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Issues: Whether a corrigendum issued after signing of an adjudication order, by substituting the operative portion to enhance duty, impose penalty, and add interest, was valid in law.

Analysis: The corrigendum was issued after the original adjudication order had been signed and sought to substantially alter the operative part by increasing the duty demand and introducing penalty and interest. Such a change was treated as more than a mere clerical correction and was considered equivalent to a review of the adjudication order. Once the adjudicating authority had passed the order, it became functus officio and had no power to reopen or amend the decision except for limited correction of obvious clerical mistakes or errors apparent on the face of the record. The Board circular and prior Tribunal decisions supported this position.

Conclusion: The corrigendum was held to be invalid and unsustainable in law, and the Revenue's appeal failed.

Ratio Decidendi: After an adjudication order is signed, the authority becomes functus officio and cannot issue a corrigendum that substantively alters the decision by enhancing liability, as such action amounts to an impermissible review rather than a permissible correction of clerical or apparent errors.

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