Rectification powers cannot be used for debatable tax issues; only patent errors on the record can be corrected.

Rectification under the income-tax law is confined to mistakes that are obvious, patent and self-evident on the face of the record; where the issue turns on competing statutory interpretations, the authority lacks jurisdiction to proceed by rectification. On the disputed surcharge computation, the text states that the question required consideration of rival constructions and was not a clerical or apparent error, so the rectification order was quashed. A party is not automatically barred in writ proceedings from raising a legal ground not pressed in revision, and the objection on that basis was rejected.

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Issues: (i) whether the Income-tax Officer could invoke rectification powers for the disputed surcharge computation on the footing that the error was apparent from the record; (ii) whether the assessees were barred from raising in writ proceedings a point not urged in revision.

Issue (i): whether the Income-tax Officer could invoke rectification powers for the disputed surcharge computation on the footing that the error was apparent from the record.

Analysis: Rectification under the relevant provisions is confined to mistakes that are obvious, patent, and self-evident on the face of the record. Where the issue depends on rival interpretations of the statutory scheme and both views are reasonably arguable, the matter is not one for summary correction by rectification. The question whether the partner's share of tax relief could be treated as unearned income required examination of competing constructions of the statutory provisions and was not a mere clerical or patent mistake.

Conclusion: The rectification order was without jurisdiction because the alleged mistake was not apparent from the record.

Issue (ii): whether the assessees were barred from raising in writ proceedings a point not urged in revision.

Analysis: A party is not necessarily precluded from challenging the legality of an order on a legal ground merely because that ground was not pressed in the earlier revision. The absence of the point in the revision application did not justify rejection of the challenge, particularly when the principal attack went to the very scope of the rectification power.

Conclusion: The objection based on failure to raise the point in revision was rejected.

Final Conclusion: The impugned rectification was quashed, and the writ petition succeeded on the ground that the disputed issue required debatable statutory interpretation rather than rectification of an obvious mistake.

Ratio Decidendi: Rectification is permissible only for a mistake that is patent and self-evident from the record; if the issue is reasonably debatable or depends on competing legal interpretations, the authority lacks jurisdiction to rectify.

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