Rectification power limited to errors in the same assessment record; extraneous material from another year cannot justify correction.

Section 37 rectification is confined to a mistake apparent from the record of the very assessment sought to be corrected. The assessing authority cannot rely on material from proceedings for another assessment year or travel beyond the relevant record to justify rectification. Because the notices and rectification orders were based on a partition deed produced in a subsequent year's proceedings, and not on any apparent mistake in the three assessments under challenge, the statutory precondition was not met. The rectification orders were therefore without jurisdiction and liable to be quashed in favour of the assessee.

---

---

Issues: Whether the Agricultural Income-tax Officer could invoke section 37 to rectify completed assessments for the relevant assessment years by relying on material found in the assessment proceedings for a different year.

Analysis: Section 37 empowers rectification only of a mistake apparent from the record of the assessment sought to be rectified. For that purpose, the assessing authority cannot travel beyond the record of the relevant assessment year or rely on materials discovered in later proceedings for another year. Since the notices and rectification orders were founded on a partition deed produced in proceedings for a subsequent assessment year, and not on any mistake apparent from the record of the three assessments in question, the statutory condition for exercising rectification power was not satisfied.

Conclusion: The rectification orders were without jurisdiction and were liable to be quashed, in favour of the assessee.

Final Conclusion: The writ petitions succeeded because rectification under section 37 could be exercised only on the basis of an apparent mistake in the record of the very assessment under challenge, not by using extraneous material from another assessment year.

Ratio Decidendi: Rectification power for a mistake apparent from the record cannot be exercised on the basis of material outside the relevant assessment record.

---