Rectification of factual and computational errors may be remanded for fresh departmental reconsideration when appellate remedy is ineffective.

A rectification application raising factual and computational errors was rejected as time-barred, and the ensuing appeal was also dismissed on limitation, even though the underlying request had not been substantively examined. Given the statutory framework, the availability of departmental records, and the absence of a constituted appellate tribunal, the matter was found suitable for reconsideration at the departmental stage. The rejection order and appellate order were set aside, and the proper officer was directed to reconsider the rectification request after granting a personal hearing. The writ petition was accordingly disposed of by restoring the matter for fresh consideration.

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Issues: Whether the order rejecting the rectification application and the appellate order dismissing the appeal on limitation could be sustained, and whether the matter should be remanded to the proper officer for reconsideration of the rectification request.

Analysis: The assessment order had been followed by a rectification application seeking correction of factual and computational issues. The rectification request had been rejected as time-barred with a direction to prefer an appeal, but the appeal filed with pre-deposit was also rejected on limitation. In view of the statutory scheme, the availability of departmental records, and the fact that the appellate tribunal was not yet constituted, the matter was considered fit for completion of the adjudicatory process at the departmental stage before the appellate remedy was pursued.

Conclusion: The rejection order dated 28 October 2024 and the appellate order dated 25 February 2025 were set aside, and the matter was remanded to the proper officer for reconsideration of the rectification application after granting personal hearing.

Final Conclusion: The writ petition was disposed of by restoring the matter to the proper officer for fresh consideration of the rectification request.

Ratio Decidendi: Where a rectification application raising factual and computational issues has not been substantively examined, and the appellate remedy is rendered ineffective by the non-constitution of the tribunal, the matter may be remanded to the proper officer for reconsideration with due hearing.

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