Rectification limited to patent errors; factual mismatches in returns cannot be reopened through rectification.

Rectification is confined to an error apparent on the face of the record and cannot be used to reopen factual disputes. Where assessment was made after a show cause notice and no reply was filed, a grievance based on mismatch in returns required examination during assessment, not in rectification proceedings. The note states that such factual controversies are outside the scope of rectification, and the challenge to the rectification order failed.

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Issues: Whether the rectification application could be entertained in the absence of any error apparent on the face of the original assessment order.

Analysis: The assessment had been made after issuance of a show cause notice and no reply had been filed. The grievance raised in rectification concerned factual matters arising from mismatch in returns, which required examination at the stage of assessment and not in rectification proceedings. Rectification is confined to patent errors in the original order and cannot be used to reopen factual controversies.

Conclusion: The rectification order did not call for interference and the challenge failed.

Final Conclusion: The writ petition was dismissed, and the connected miscellaneous petitions were closed.

Ratio Decidendi: Rectification can be invoked only for an error apparent on the face of the record, and not for adjudication of factual issues that ought to have been raised in the assessment proceedings.

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