Corrigendum cannot create fresh duty liability through substantive changes; review is required for material alterations.

A corrigendum cannot be used to impose additional duty liability by making substantive changes to an already issued order; its scope is limited to clerical or typographical corrections. Where significant alterations are required after the original order, the proper course is review rather than corrigendum. As the corrigendum was issued nearly two years later and materially changed the original order, the authority acted beyond its power. The corrigendum was therefore invalid and was rightly set aside in favour of the assessee.

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Issues: Whether the adjudicating authority could issue a corrigendum that created additional duty liability by making substantive changes in the original order.

Analysis: The corrigendum was issued nearly two years after the original order and was found to make substantive alterations rather than merely correct clerical or typographical mistakes. The Board's circular indicated that where significant changes are required after an order has been issued, the proper course is to seek review instead of resorting to a corrigendum. On that basis, the authority was held to have acted beyond its power.

Conclusion: The corrigendum was invalid and was rightly set aside, in favour of the assessee.

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