Rectification for apparent error cannot reopen time-barred refund claims or issues needing extended reasoning under excise law.

Refund claims were restricted to amounts covered by the statutory six-month limitation period, and earlier claims remained barred even though they were said to have been filed pursuant to Supreme Court directions. A rectification request under Section 35C(2) of the Central Excise Act, 1944 could succeed only if there was a mistake apparent from the record; an error needing long-drawn reasoning did not qualify. On that basis, no apparent mistake was shown and the rectification application was untenable.

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Issues: Whether the refund claims were confined to the statutory limitation period and whether any mistake apparent from the record existed so as to justify rectification under Section 35C(2) of the Central Excise Act, 1944.

Analysis: The refund applications could be considered only to the extent they related to claims filed within six months immediately preceding the respective dates of application. Earlier claims remained barred by limitation, and the fact that the applications were said to have been filed in compliance with directions of the Supreme Court did not exclude the operation of the limitation period. A rectification application under Section 35C(2) cannot succeed on the basis of an error requiring long-drawn argument, because such an error is not a mistake apparent from the record.

Conclusion: No mistake apparent from the record was shown, and the rectification application was untenable.

Final Conclusion: The application for rectification failed on limitation as well as on the absence of any apparent error, and the relief sought was refused.

Ratio Decidendi: A rectification under Section 35C(2) of the Central Excise Act, 1944 lies only for an obvious error apparent from the record and cannot be used to reopen claims barred by limitation or to decide issues requiring extended reasoning.

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