Rectification requires a patent record error; refund interest and valuation objections were not open to review.

Rectification is unavailable unless the alleged error is a patent mistake apparent on the face of the record; fresh arguments, omitted authorities, or reappraisal of merits cannot be addressed in rectification proceedings. Interest on refund was not a rectifiable error because delayed-refund interest is governed by Section 27A of the Customs Act, while the Tribunal's remedial power under Section 129B does not extend to awarding interest at the claimed rate without statutory basis. Non-consideration of an unrelied valuation precedent, and of valuation objections already dealt with in the earlier order, likewise did not constitute an apparent mistake.

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Issues: (i) Whether the omission to award interest on the refund amount constituted a mistake apparent on record warranting rectification. (ii) Whether non-consideration of the cited valuation precedent and related valuation objections amounted to a mistake apparent on record.

Issue (i): Whether the omission to award interest on the refund amount constituted a mistake apparent on record warranting rectification.

Analysis: Interest on delayed refund is governed by the statutory scheme under Section 27A of the Customs Act, 1962. The Tribunal's power under Section 129B of the Customs Act, 1962 is confined to confirming, modifying, annulling, or remanding the appealed order. The directions relied upon by the applicant arose in writ jurisdiction under Article 226 of the Constitution of India, and no statutory basis was shown for the Tribunal to award interest at the claimed rate from the date of payment of duty.

Conclusion: The omission to award interest was not a mistake apparent on record, and the claim for rectification failed on this issue.

Issue (ii): Whether non-consideration of the cited valuation precedent and related valuation objections amounted to a mistake apparent on record.

Analysis: The cited decision on valuation had not been relied upon at the hearing of the appeal, and therefore its non-consideration could not be treated as an apparent mistake. The remaining valuation submissions had already been considered in the earlier order, and the Commissioner (Appeals) had accepted the declared price on the reasoning recorded in the appellate order. Rule 8(2)(iii) of the Customs Valuation Rules was also relied on by the applicant, but the Tribunal found no omission that justified rectification.

Conclusion: The alleged valuation error did not disclose any mistake apparent on record, and the rectification claim failed on this issue as well.

Final Conclusion: The application was held to be without merit because no apparent error existed in the final order either on interest or on valuation.

Ratio Decidendi: Rectification is unavailable unless the alleged error is a patent mistake apparent on the face of the record; matters requiring fresh argument, reconsideration of omitted authorities, or a new appraisal of the merits cannot be corrected in rectification proceedings.

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