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Issues: Whether the final order contained a mistake apparent on the face of the record in stating the relevant six-month limitation period under Rule 57G of the Central Excise Rules, 1944.
Analysis: The extract from the earlier order showed an inconsistency between the finding that credit was taken six months after receipt of inputs and the later recital suggesting a six-month period from the date of the show cause notice. The record also showed that the intended reference was to six months from the date of receipt of inputs. Since the operative reasoning was inconsistent in two material respects, the mistake was held to be apparent from the record and amenable to rectification.
Conclusion: The rectification request was allowed and the extracted portion of the earlier order was modified to clarify that the reasonable period of limitation was six months from the date of receipt of the inputs. The application succeeded in favour of the assessee.
Final Conclusion: The order was corrected to align the limitation reasoning with the recorded facts, and the rectification application was granted.
Ratio Decidendi: A patent inconsistency between the recorded facts and the stated legal basis in an order constitutes a mistake apparent on the face of the record and may be rectified by clarifying the intended legal position.