Rectification not available for missing point-by-point discussion when relevant submissions were already considered and classification reasoning was recorded.

An order is not liable to rectification merely because it does not separately refer in the concluding findings to every written submission, HSN entry, cited decision or notification relied upon by a party, where the relevant material was already considered in the earlier discussion and findings. A rectification application cannot be used to obtain a rehearing or to demand a point-by-point restatement of the reasoning. The document also states that an exemption notification cannot, by itself, be the basis for determining tariff classification. On that basis, no mistake apparent on the face of the record was established and rectification was not warranted.

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Issues: Whether the final order suffered from a mistake apparent on the face of the record because it did not separately deal with every submission, HSN reference, case law, and Notification No. 117/94 relied upon by the applicant, so as to justify rectification.

Analysis: The application arose out of a classification dispute. The material relied upon by the applicant had been noticed in the earlier order, and the dispute had been dealt with in the relevant paragraphs containing discussion and findings. The omission to make specific reference in the finding portion to each written submission, each HSN entry, or every cited decision did not show that the submissions were ignored. A rectification application cannot be used to seek a rehearing merely because the reasoning is not elaborated point by point. The reliance on Notification No. 117/94 was also held not to assist the applicant because an exemption notification cannot be the foundation for determining classification.

Conclusion: No mistake apparent on the face of the record was established, and rectification was not warranted.

Ratio Decidendi: An order is not liable to rectification merely because it does not expressly answer each submission or citation, if the material contentions were considered and a reasoned conclusion was recorded; an exemption notification cannot by itself determine tariff classification.

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