Rectification is confined to apparent mistakes; enhanced compensation remained includible in net wealth, so review-style relief was denied.

Rectification under section 254(2) is limited to mistakes apparent from the record and cannot be used as a review mechanism. The Tribunal held that the assessee had not shown any patent error in the earlier order concerning inclusion of enhanced compensation in net wealth. It accepted that the right to receive compensation is a single property right valued with reference to the relevant notification and valuation dates, and that later enhancement relates back to the earlier date. On that basis, the inclusion of the compensation amount was not established as legally or factually mistaken, and rectification was refused.

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Issues: Whether the assessee's miscellaneous applications disclosed any mistake apparent from the record in the Tribunal's earlier order so as to justify rectification of the inclusion of additional compensation in net wealth.

Analysis: Rectification under section 254(2) is confined to mistakes apparent from the record and cannot be used to seek a review of the earlier order. The Tribunal held that the controversy was not a patent error. It accepted the view that the right to receive compensation is a single property right valued with reference to the relevant notification and valuation dates, and that the later determination of enhanced compensation related back to the earlier date. On that basis, the inclusion of the compensation amount in net wealth was not shown to be legally or factually mistaken.

Conclusion: The assessee was not entitled to rectification, and the miscellaneous applications failed.

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