Rectification jurisdiction under section 254(2) is limited to apparent errors, not debatable issues or merits reargument.

Rectification under section 254(2) of the Income-tax Act is confined to patent, obvious mistakes apparent from the record and cannot be used to reopen debatable issues or reargue the merits of the original order. Allegations of non-exercise of powers under section 131 read with section 255(6), improper appreciation of an affidavit, and non-consideration of precedent were treated as matters involving disputed facts and legal debate, not apparent errors. In section 260A review, interference requires a substantial question of law, and no perversity or procedural illegality was shown. The Tribunal's refusal to rectify was therefore upheld.

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Issues: Whether the Tribunal's refusal to rectify its order under section 254(2) of the Income-tax Act, 1961 suffered from any mistake apparent from the record, including alleged non-exercise of powers under section 131 read with section 255(6) and alleged non-consideration of the affidavit and supporting legal precedent, so as to justify interference under section 260A.

Analysis: Section 254(2) permits only correction of patent, obvious and self-evident mistakes apparent from the record. Errors requiring elaborate argument, factual reappraisal, or examination of debatable legal issues do not fall within rectification jurisdiction. The challenge based on alleged non-exercise of investigative powers, the manner of appreciation of the driver's affidavit, and reliance on precedent all depended on disputed facts and debate, and therefore could not be treated as apparent mistakes. In an appeal under section 260A, interference is warranted only where a substantial question of law arises; no perversity or procedural illegality in the Tribunal's view was shown.

Conclusion: The refusal to rectify was upheld, and no substantial question of law was found to arise. The outcome was against the assessee and in favour of the Revenue.

Ratio Decidendi: Rectification under section 254(2) is confined to manifest errors apparent from the record and cannot be used to reopen debatable issues or reargue the merits of the original order.

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