Rectification of mistake is not a rehearing on merits where the original order already addressed limitation and record-based findings.

Rectification under the CESTAT's limited correction power is confined to mistakes apparent from the record and cannot be used as a substitute for appeal or review. A debatable issue, or one requiring reappreciation of evidence or elaborate argument, falls outside that scope. Non-dealing with every submission or cited case law does not by itself create a rectifiable error, especially where the original order had already addressed limitation on the basis of departmental knowledge, recorded statements, and documents on record. The Revenue's applications therefore sought a rehearing on merits rather than correction of any patent or clerical mistake, and were not maintainable to reopen the earlier final order.

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Issues: Whether the Revenue could maintain rectification of mistake applications to reopen the earlier final order on the ground of alleged non-consideration of submissions, case law, and limitation findings, and whether such alleged omissions constituted a mistake apparent from the record.

Analysis: The Tribunal reiterated that rectification is confined to errors apparent on the face of the record and cannot be used as a substitute for appeal or review. A point requiring elaborate argument, reappreciation of evidence, or reconsideration of a debatable issue does not fall within the narrow scope of rectification. The Tribunal further held that non-dealing with every submission or case law cited does not by itself create a rectifiable error, particularly where the earlier order had already addressed the limitation issue on the basis of the departmental knowledge, the statements recorded, and the documents placed on record. The cited authorities on apparent mistakes, functus officio, and the limited correction power supported the conclusion that the Revenue's grievances sought a rehearing on merits rather than correction of an obvious clerical or patent error.

Conclusion: The rectification applications did not disclose any mistake apparent from the record and were not maintainable for reopening the merits of the earlier decision.

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